Name: Domestic Content & FEOC guidance for TPO with LightReach
Uploaded: 2025-10-30T20:16:02.670Z
Duration: 53 min 16 s
Description: Domestic Content & FEOC guidance for TPO with LightReach

Transcript for "Domestic Content & FEOC guidance for TPO with LightReach": Hi, folks. Welcome. For those of you coming in now, just letting you know we're gonna give people another minute or two to join, and then we will be kicking off. Okay. I think we're gonna dive in. Welcome. So today, we have a discussion on FIOC domestic content and safe harbor, a very timely discussion, in collaboration with LightReach | Palmetto and, some from Aurora, which is my side. Today, we've got myself. I'm Mackenzie Siren. I'm a staff product manager on the Aurora Solar team, and we got Sean. Oh, Sean, you might be muted. Okay. We'll work on that. I'll introduce Sean. So Sean Hayes is a senior vice president, and general manager at LightReach | Palmetto. So we'll be hearing from him in a moment. He'll work through his technical difficulties. So I'll review the agenda, and then I have a couple notes on the presentation before we dive in. So today, we'll be talking through, FIOC, domestic content and safe harbor, which, no surprises, is the, is the theme of today's, conversation writ large. But we'll be going through fairly specific, guidance and next steps around these topics, from the LightReach side of things and then also talking through how Aurora is supporting, you know, these hot button topics through things like AVLs which is approved vendor lists and domestic content component guardrails. And then we're gonna leave time for q and a at the end. Alright. A couple notes before we dive in, that are important to cover. Please do not take screenshots, or share documentation from this presentation outside of your organization. Note that anything we're discussing today, we're not providing tax advice. We're sharing guidance around the Light Reach program, and please expect that the, fee off and domestic content policy will continue to change. We've already seen this a lot in the last, you know, couple weeks and months. So we're gonna work with you, LightReach in particular, work with you to communicate to all of the partners, in a transparent and timely manner when they do change and how that sort of impacts your components, and the the guidance on how to remain compliant. So please keep these things in mind as we go through sort of the next steps of this process. Awesome. Sean, how are you doing on your side? I'm here. Can you hear me? I can hear you. Excellent. Okay. Great. I will hand it over to you. Awesome. Awesome. Yeah. Thank you so much, Mackenzie, and appreciate the the broader Aurora team for for having us on here today. Very much appreciate the partnership, and, thank you all for for jumping on. To to get us kicked off, I think, was reflecting, and I was joking, that I have spent more time talking about equipment, fee, domestic content, and safe harbor over the last sixty, ninety days than I have to my actual wife. So, gonna do my best to distill, a lot of, what I've been, spending a good bit of time on here today for you all, and and hopefully, we leave with a better understanding of of some of these, complex, issues, that we are, we are ready to navigate. So, let's let's jump in. So I think to get started, I just level setting with three core concepts that we're gonna talk about here today. First and foremost, you're gonna hear a lot of foreign entity of concern, FIAC. What is FIAC? So, FIAC is specifically talking about who owns the actual companies in the supply chain. It is not where it's manufactured. It is physically the location of the ownership of said, supply chain. So in 2026, there is a this is a new concept that that we will have to navigate to be able to qualify for the investment tax credit. There is a percent of a project's value that cannot be tied, to a prohibited foreign entity. So you if you hear prohibited foreign entity PFE, that is, South Sudan, China. There's not any manufacturing of solar products yet in South Sudan. So largely, we are focused, in talking about China, connective tissue to China. So lots of fiat. Domestic content. Domestic content is specifically, where the equipment is actually manufactured. So, again, with the tax credit, there is actually an additional value if you are utilizing, equipment that does, qualifies domestic content and is manufactured here in The US. And then lastly, safe harbor. So the concept of safe harbor, is a new one, as well as it relates to sort of the the residential solar space and and some of the things that, we will be, working through in in 2026 and beyond. And and really what, safe harbor is, speaking to is is it's the commence construction, related to equipment purchase. And all of that is to secure the tax credit, and extend it beyond the current time, where it will come to an end, at 2027. So if you were looking to monetize a 30% investment tax credit beyond 2027, which you can, via safe harbor, that equipment must be purchased by 07/03/2026. So we'll talk a little bit about, safe harbor strategies there and, what what it means for us, going forward. Alright. Goals. Three of them. So first and foremost, we at LightReach are focused on ensuring that all jobs are FIAC compliant starting 01/01/2026. So, again, FIAC restrictions and governance starts 01/01/2026. So we are sort of core is make sure that you secure the actual 30% tax credit. In order to do that, you must be FIAC compliant. Next is, sort of, a value add that we think is worthwhile in pursuing, not a requirement, but an option, which is domestic content. So we're trying to give you all, as much advice and guidance as far as how, and what, to do, to secure domestic content. And then lastly, again, we want to give some guidance on our safe harbor strategy, that's already been enacted, which is aimed, you know, kind of both at supporting domestic content achievement and FIAC compliance. Alright. I am just taking a step back. There is a lot of moving pieces in, the world, today, and those moving pieces, I sort of I give bad analogies all the time. So, I'll I'll here's here's one for you all, that are Harry Potter fans. I feel like, the current sort of Fiat, landscape is kinda like I'm at Hogwarts and I'm on a staircase. I think I'm going to the Second Floor, but it moves and I end up on the Fifth. So, sort of, in doing our best to navigate, all of these challenges and provide you all as much information as we can, but just be cognizant of the fact that, there's still a good bit of uncertainty out there, both on the political front, but also on the OEM front. So the information that we are getting, has to originate from the OEMs. They're the ones who are helping us understand is your organization and the supply chain you use. What what is the connective tissue, to China. And so we are we are relying on them to fill out scorecards, and there's lots of information, that that we are kind of working with them in in tandem to obtain. And then, in turn, third party consultants, specifically Deloitte, to help ensure that, everything we are interpreting, and driving and understanding around is also double stamped by, their expert, expertise. All of the while, these these things that may change, good news. We maintain, a fairly robust knowledge base, and we publish a lot of these changes, as quickly as we can. So news.go lightreach.com, is sort of our, place that we, lean into to help give you all, as much, kind of real time insight as things change as possible. Alright. Four core challenges, that that, we, at the LightReach side are trying to, attack here. So first and foremost, as you all know, the, 48 e, the specific tax credit that, residential third party ownership, providers utilize, that expires 12/31/2027. So, what that means is that if you do not take any action with Safe Harbor, you will not be able to get a 30% tax credit after 12/31/2027. So our goal, with safe harboring is to safe harbor projects that allow us to extend that tax credit through, 2030, so giving us a few extra years of runway. So first and foremost, that's kind of the core area that we initially aim to attack. Second is Fiat. So the Fiat requirements, there is a lot stricter governance on equipment. I have been in the space for twelve years. I have never seen as much, you know, kind of nuance around equipment supply chain, specifically modules, than I have, this year and and heading into next. So really, want to do our best to ensure that everyone is super clear on the implications of Fiac, what it means, and, of course, how to navigate it and ensure that you continue to keep your installations rock and roll. Domestic content, again, we are, trying to provide feedback on how to achieve domestic content, what, what actually classifies as domestic content when those thresholds change. How do we go about ensuring that folks are clear, as to what needs to be done to continue to meet those domestic content thresholds and potentially qualify for that additional adder? And then lastly, again, sort of to my earlier comment, with the end of year push to get as many cash and loan jobs installed, you've got a lot of stress on the module supply chain. And then on top of that, you know, obviously, the QSells challenges and and their stuff getting stuck at port. You have, what is 30 to 40% of the residential solar, module market kind of, that has been hamstrung and not able to get as much product into warehouses as they otherwise would. So those kind of factors in addition to Fiat, which is pushing some historical, panel providers out of the market because they are not Fiat compliant. There's just, there's a there's a big rush, to get modules. And so trying to do our best, to navigate that challenge alongside of you all. Alright. Taking a deep breath, everybody. We will figure it out. Have some confidence. Let's get into some some details here. So the the the fun thing, the IRS has provided guidance that has said in order to understand, who qualifies, as nonFIAC or as fiat compliant, please use the domestic content tables that we have published. And so that is what you're seeing on screen here. These are the domestic content tables. And then you may be thinking to yourself, well, didn't you say domestic content is different than FIAC? I did. And that is true, but the IRS is saying use the same tails. And so let's talk about that. This is specifically saying, in particular, the cells. Okay. The cells. Where are the cells, manufactured? Nope. That is domestic content. It's who has actually manufactured it. So in this instance, the example I'll give is is is Hyundai. Hyundai is an entity that is clearly South Korean, but Hyundai has a bunch of subcontractors that you they utilize to obtain the materials that they use to, manufacture a a panel. And so if if Hyundai, the entity that is is, domiciled, and the ownership is in South Korea, if they utilize cells in their panel and the the the cell manufacturer is Chinese, that is considered, you basically do not qualify for that 31.1. And so, cells are out. Next up, you go down to frame and back sheet, and you say, the entity that manufactured that frame and back sheet, where is that ownership? And does it have any connective tissue to China? Yes or no? And so you do that for every single one of these steps. And then you understand at the bottom, did I get to a value that is above what is classified as, Fiat? Yes or no? And so you'll see that depends whether you're using an MLPE, so module level panel electronics, or if your inverter is a string inverter. And so these these change the dynamics change based on, again, MLPE and string. But the the fundamental thing that you all should just the takeaway here is it is who manufactured the component, not where it's located. So, keep that in mind. I'm not gonna go through each and every one of these, but these are the questions that we are asking every single OEM that we work with, specifically in the module side, because that's where the most, connective tissue is back to, China owned organizations. Alright. So this is, us doing our best to, navigate, and provide some insights as far as we have done a lot of work, still work to be done on who is Fiat compliant based on, again, the diligence alongside of Deloitte and the OEMs, and who are we uncertain with. So as it stands, REC, Qcell, Silfab, Hyundai, and Sirius, we believe will be Fiat compliant based on the information and all of the work and research that we've done thus far. So, when you're looking at your supply chains, REC, Qcell, Silfab, Hyundai, Sirius, we feel very good about those specific manufacturers and being Fiat compliant. There are two that we are working very closely with, that we have not yet gotten the final certainty on, but are hoping to, but, again, remains uncertain, and that is SEG admission. So, if the the panel manufacturer is in green, you should feel quite good about them being FIAT compliant. If they are not in green, that's not to say they won't be FIAT compliant. Just We don't have enough information at this current time to give you that thumbs up. So, when you're making panel decisions, our best, recommendation is use somebody in green. Again, the guidelines that we are giving our partners, the LightReach partners is, as of January 1, just like the IRS guidelines say that you need to be fiat compliant, we are that's what we're enforcing. So we're saying any installs that occur, and are submitted to us 01/01/2026 and beyond, we really, are requiring them to be Fiat compliant. Alright. Trying to boil all of these moving parts and pieces down and kinda give you guys some guidance on a recommended BOM combination. So, again, the guidance changes based on whether using MLPE or string inverters. So that's sort of the anchor for this discussion is, is this, MOPE or string? So if I were in your all seats, the, the simplest way, nothing is ever simple, but the the simplest way from from what we know to be FIOX compliant with the bomb, it is this. It is using an enphase SolarEdge or QCELL's domestic content inverter. It is using racking that is also domestic content, and then it is using a panel that is FIAC compliant. That FIAC compliant panel over on the right, REC, q sales, self help, Hyundai, Sirius, is sort of the, what I think based on the availability of material, that is the best way to have confidence in a BIOC compliant volume. Enphase SolarEdge q cell's domestic content, racking is domestic content, and a panel over on the right. So that is that is the most, that that is sort of taking a step back, probably the the, most attainable path to have confidence in FIAC. Now that's not to say you can't get there with string, inverters, and or firewall threes. It's just a little bit harder. It's a little bit harder because not only do you need a panel, on the right hand side, r e c q cells, so if I'm on that series, that panel also needs to have, a non PFE content of 12.1 or higher. So those do those do exist. There's just less of them out there. So, again, it is possible to qualify with string. It's just you also have that added degree of complexity that you need a panel in green, and that panel also needs to have, non PFE content greater than 12.1%. So, again, there's just less of those out there right now, as it stands. On the battery, we feel very good, from the information we have, to date on Enphase Tesla, Powerwall three and SolarEdge. The batteries specifically, should be, Fiat compliant, in 2026. The the key thing, that we're working through in particular with SolarEdge is I think the the first half of the year, SolarEdge's battery, we, will will not likely be Fiat compliant. And so there's a there's a safe harbor strategy there, that, that we're hoping to, execute here, I think, as of, today or tomorrow. So, we'll have optionality with with solar batteries in compliance, by way of safe harbor. Alright. I'm not ignoring questions. I promise. But I am, would say that I'm gonna get through all this material, and then we will come back to questions. So I really appreciate all the engagement, and thank you for for dropping them. I'm not ignoring you. I just, may hit some of these questions with the material and the content. So, I wanna wanna blaze through that first and foremost, and then we can come back, and and go through the the q and a. Alright. One thing that I would say, there's a lot of nuance in in in information that I'm throwing at you. So, I know it's a lot because, I've spent the last ninety days, working through it and and and sort of finally there as far as, you know, understanding all of the the the the nuance. We are in the process of building a FIOCC calculator in our portal. So if you are a LightReach partner, we are attempting to do very similar approach to what we did with our domestic content calculator, which is the screenshot you can see, whereby an installer can come in, enter, the specific equipment details, and we will produce, a green yes. This is Fiat compliant or, a red flashing no. This is not Fiat compliant. So, this technology work is underway, and we hope to have this in our portal, in the next thirty days. That's not to say we're not giving you enough information today to make decisions, but it's to say we're attempting to build this in the portal so that, it is very, very black and white, and you can get the inform the information, directly from us in that fashion. So in progress, hang tight. There will be a Fiat calculator that, looks very similar to our current domestic content calculator. Alright. Nearly there, team. So thanks thanks for for hanging in. So domestic content, and Fiat compliant panel supply is, we're just raising our hand saying we think this is one of the biggest challenges that our installation partners are facing, and so we're doing our best to answer and publish as much guidance and information as we physically can, with with what we have out there. So, raising our hand and saying we know that there's a lot of uncertainty and challenges associated with with FiOC, compliant panels and just the general panel supply out there, and we're trying to help to with what we can, in a couple different ways. So, one, we have, been working closely. We've got a lot of really awesome distribution partners out there. So we've been, working to to sign supply agreements with them. Distribution partners have incredible buying power with some of those, Fiat compliant modules that we've listed earlier, Qcell, Silfab, REC, Hyundai, and Sirius. And so the supply agreements are aimed at helping us, allocate and reserve, supply so that you all have confidence as you step into q one for those modules. And similarly, we, have and will continue to execute safe harbor agreements, with pretty much, every inverter manufacturer and battery battery manufacturer on our AVL today, so that you all can have confidence in a a runway that goes through 2030, with the LightReach, TPO product. So, again, safe harbor strategy is one that we've been, focused on, executed. We've made buys. We have material, and we will continue to do that, up until the deadline, which is 07/03/2026 for those, safe harbor solutions. So, again, if if if you didn't have this takeaway yet, our AVL on the module side is shrinking in 2026. We wouldn't do this if we didn't have to, but because of PHEAC, we are shrinking our module AVL. So if you're using Longy, Jinko, J, Trina, Canadian Visa, and Maxion, it's not that we don't think that is a good product. That's not what we were saying. We are just saying that that as it stands with the information we have today, it is not Fiat compliant, and therefore, we will be, pulling it from our AVL. So, again, that is the main takeaway here. The AVL will be getting smaller. And if you have been relying on these, those specific manufacturers, you will need to pivot, for installs that you submit to us in 2026. Alright. How there's there's a lot of doom and gloom, but but remain optimistic, remain confident. We are, we feel pretty good about, the the optionality that that is, coming on the module front in '26. We're working tirelessly with, again, our distribution partners and the OEMs to ensure that we have stock and that you all have access to those panels. So if if you are struggling or haven't gotten the warm and fuzzies yet, you know, hang in there. We are doing our best, and and trying to navigate this, so that you all have have material, as you step into, into the new year. The other thing I would say is that we are working, through some creative, strategies whereby we may, in certain circumstances, make safe harbor material available, to help plug some of the short term gaps with with these modules. So, that's something that we are also, you know, being mindful of in in certain ways, across the country if if there is, some severe panel shortages that that we don't have the confidence, will be solved. So, we do have a few other solutions, in our back pocket on that front. I would say that the best thing you can do, communicate with your distribution partners. Things change daily, and continue to to talk with your relationship managers if you work with us. If you don't work with us, that's okay. I won't hold it against you, but do what you can to to communicate with your distribution OEM partners. Again, it's a very fluid situation, and they're they're doing their best to keep this information, as as top of mind for you all as as they can. Again, stick to the recommendations we've given you. We, are doing what we can to podcast as openly as we can. As far as what modules you can use that we will accept if you use a module that is not on this list. Then there's going to be some challenges. So do what you can, to use modules on this list. And just be mindful that, we are getting information and digesting it as quickly as we can. We're not holding anything back. We promise, if there's information, we are packaging it up and sharing it with our partners in the field as quickly as we can. And lastly, have the confidence, the LightReach business has safe harbored, lots of products, that will allow us to extend the, investment tax credit into 2030. So there is a long, fruitful runway for all of us, through 2030. So hopefully that, I'm doing a webinar in 2030 about, some other exciting development between Aurora and LightReach that is not related to, Fiat and panels. So that is, that's the primary, material that I wanted to cover. This FAQ is sort of redundant and and, I'll leave it on the screen, but it's a lot of what what we just covered, just in a recap fashion. So, Mackenzie, if it's okay with you, is now a good time to start to jump into the, the q and a, or do you wanna talk through anything on your side first? Mackenzie, it might just be me, but I can't hear you. I was muted. No worries. Now? I got you. Excellent. Okay. Sorry about that. Yeah. I was gonna say, I'd love to run through just a couple slides before we dig into q and a to let folks know how we're going to be, able to sort of handle this moving, landscape of policy changes and guidance in the Aurora platform, sharing some stuff we've already done and some stuff that we have coming up, in the next couple of months, and then let's dive into q and a together would be my suggestion. Great. Yeah. Sounds good. Okay. Great. So I think you had one more here. A thank you. Yes. Yes. I don't know if there's any distribution partners that are on here or OEM partners, but we have been, we are super thankful of all the support, that they have given us. We've been hammering them with millions of questions. They have been awesome. So, also, if you see them in person or you're at a GreenTek, warehouse, Sonopar, so, like, hug hug your distribution rep. They're they're doing what they can to fight in the trenches for you also. Just just a final thank you. So appreciate it. Awesome. Thanks, Sean. Okay. So just a couple quick slides here on, basically, if if you're using their platform, right, how can you ensure that your team is using the right equipment? Given all of these sort of changing landscapes and rules, we want to make sure that folks are able to make the best choices for designs and proposals. So going through just a couple quick slides on what we're changing in the platform. Alright, so this first one. In our last webinar with LightReach a few weeks ago, we walked through how the LightReach and Aurora integration works. So now I want to highlight a few of the enhancements we're working on to remove any friction and uncertainty in your sales and design process process when selecting equipment. So today in Aurora's component database, account admins are able to see which components are included on LightReach ADL and enable those components for their team use in the database view. Then when users are creating a system design, they can click on the LightReach | Palmetto tab in the approved vendor list area, to make sure they're using components on the LightReach AVL as you can see sort of on the right here. So we've been working a lot behind the scenes on, on basically AVL maintenance writ large. We wanna make sure that the AVLs you're seeing in the Aurora platform are as up to date as possible. So we're staying in constant contact with LightReach and our other partners and reflecting those changes in Aurora, within a day or two. So we're really trying to streamline that process on the back end to make sure that you're seeing the most up to date information. In addition, we'll be getting into this more in a little bit, we're gonna introduce new functionality, so ability to tag components in the database that qualify for domestic content and then also specify which regions or AVLs you want that component available in. So the hope here is that gives you a lot more flexibility to adapt quickly as guidance or supply changes. So let's actually dig in and take a look at that now. I will move up a slide. Perfect. So this is, a design that we're actually working on right now. So Aurora maintains a database of over 15,000 components, that can be used in your designs. For every component, you're able to see which AVLs it's included on and you can enable those for your team. So that functionality already exists. So now we're introducing sort of additional component guardrails on top of that, so configurations to help make your team more confident about what equipment they're selecting in the field. So the first thing that you'll see on this slide is the ability to specify the visibility of that component by state. So if you were to leave this blank, it would be available for all or you could select a subset of states, and then that component will only be shown for projects with addresses that are located in the specified states. So trying to add more regional flexibility for folks that need those extra guardrails. You'll see, like, lower in that design, you can tag whether or not a component meets domestic content criteria at an organization level. So whether on sort of the all modules or all batteries tab, you want that to show up with an indicator. And then additionally, you can control whether an approved component from an AVL, if you actually want that visible on the AVL, either by region or for all, So whether or not it actually surfaces on the tab for your sales team and your designers and then whether or not it meets domestic content criteria for that AVL. So this configuration is managed on every different AVL. So LightReach will have their own configurations and other ones will have different ones. So trying to bake in a lot of flexibility here. So this is what it looks like on the admin side. We'll take a quick look here at sort of how this will float up, to folks in the field. So a sales rep or a designer, when they're selecting equipment to use in their design, they can click on the Palmetto Light Reach tab in the AVL, and they'll see the following things. So they'll see a list of components that you've enabled from LightReach AVL. So basically, these are things that are approved from LightReach and you've selected to make them visible on that AVL. The list will be pre filtered based on the state that the project is located in if you've enabled that feature for that component. And finally, you'll see here there are little tags that indicate which components meet the domestic content criteria. So this all comes together really to give admins control over which components they want their team to use and be able to quickly adapt as guidance changes going in and and sort of quickly updating where these are visible, where they can be, whether the domestic content criteria is met or not, and really sort of simplifying it for the folks that are making those decisions either during the design or proposal phases. Alright. Last one here. So just to sort of, juxtapose this against how we're handling ABL, it's slightly different. So we're working directly with LightReach to make sure you're always seeing the most up to date list of their approved components. So in the AVL situation, the information is going from LightReach, the financer, to Aurora Solar and Aurora Solar Aurora Solar is surfacing that to installers through our platform. But domestic content is a little bit different. We're not going to define which components meet domestic content criteria in our platform. So we're not going to consume that information directly from LightReach and surface it through the platform, but rather we're building what we just walked through. So really providing you the tools to make those determinations yourself, to make those decisions on the back end and surface them for the folks that, need those guardrails in order to make the right decisions. This allows you to be able to react and adjust to the most recent guidance from financers and ideally provides you with enough configurability and visibility to make sure those changes are done easily and are surfaced quickly. So the moment you change this, it will update what reps are seeing in the field. So we really wanted to sort of remove us as the the middle, middleware there and be able to let you reflect, the guidance as soon as you're getting it from, from your partners. Okay. Now we've got a healthy amount of time left. So I'd say now that we've sort of walked through how Aurora Solar is going to be handling, capturing and surfacing, these decisions in the platform, I think it's probably time now that we dig into some q and a. So I've got the list pulled up. Sean, I think, not surprisingly, you went through a lot of detailed content. So a lot of these are geared towards you. Yes. I I'm, I'm happy to jump in and and, I've got some support from from the team, answering these. But, yeah, I'll, I'll I'll read it aloud, and then and then provide provide a reply. We'll we'll do what we can to to get through as much of these as possible. Alright. Can domestic racking be safe harbored? Theoretically, you can safe harbor anything. The safe harbor approach that we have taken is focused on inverters and batteries. So I would say that that that is the approach we've taken. The reason behind that is, because that is, when you when you safe harbor something, you then have to ensure that you have tracking and ability to tie that specific products back to when you safe harbored it. With racking, that is a very, very hard thing to do, as we've as some folks have seen with the domestic content and just some etchings on the side of a of a rail. So, we you can. We have not taken that approach. We've safe harbored inverters, and that has been, the the mechanism, inverters and batteries because, again, they have monitoring IDs. It's a little bit easier to track. So that's been the approach that we've taken. Alright. Will you be upcharging the equipment in safe harbored? So one, taking a step back. The safe harbor strategy that we have employed is, is is a is a hybrid approach where it's like really, again, safe harbor material is an absolute must if you're, placing a project in service after 2027. So if you're placing a project in service in '28, '29, or '30, you must be using safe harbor equipment for it to qualify for that tax credit. And so our general view has been that's the focus that we have spent, that we want the safe harbor equipment to go to, as opposed to using it, you know, in '26 and '27 when the tax credit is still available. However, safe harbor strategies can be used, this is another question, to mitigate some of the fiat nuances. Because, again, if you safe harbor in 2025, you're safe harboring before fiat is enacted. And so, technically speaking, you can bypass those all the Fiat Nuance with the safe harbor product, from 2025. But that, the intent from our side is is is focused on extend the ITC as as long as we can, through 2030 with with, with our safe harbor efforts, more specifically. On the upcharge piece, though, the intent from our side is not to upcharge, more than the costs that that we have, incurred. So, there's additional warehousing fees. There are other fees that you incur when you've got products, that you're safe harboring. And so our intent there is we're not trying to to make margin on safe harbor product. We're just trying to recoup the the the general cost that they're incurred there. I don't expect those costs to be huge, by the way. Just, we will provide more information as, folks, who are using safe harbor equipment, get tagged in. But, again, there's not gonna be a ton of safe harbor equipment used in '26 and '27, and that fee, will will not be aiming to to make a margin off of. Can FIAC be avoided by buying components starting in construction '25? Yes. Of course. So, again, you can avoid FIAC, if you're using the safe harbor equipment in '25. What I would say in one of my observations, a lot of the Fiat, panels, so, Jinko, Trina, Canadian Solar, like, very, lots of linkage to Chinese owned entities, they're just not really coming to play in the market in '27, '28 '26, twenty seven, twenty eight, twenty. Like, what we've observed in our discussion with distribution partners is, we've just seen that a lot of those, a lot of those module manufacturers are are turning their attention to to c and I or or other global markets. So there there really isn't going to be a ton of, based on what we've seen in our discussions, a ton of what would be classified as FIOQ products, even available, as a chance. Does FIOQ affect the subcomponents used in products? So, yeah, I would say that the, the they do affect the subcomponents of products, and that's sort of why, we are spending as much time with our OEMs and going through and understanding all, of the various components and, who is the entity that is manufacturing it and are is that entity FIAC or not? And so I think we're we're doing all of that work on our side alongside of, Deloitte, so that that you don't have to. But, yes, it will affect a lot of the subcomponents. Why SCG admission in uncertain? They're in uncertainty because we don't yet have enough information from them to determine that they are, going to be Fiac compliant. So we are actively working with both of them, and they have been super helpful in getting us information, but we just do not have enough information to be able to confidently give that thumbs up yet. So, actively trying to get there, but don't yet have have enough details. And when we do, we will certainly publish information, but, hang tight, on that one. I think we already answered this. Yeah. Equipment manufactured 2025 purchased. Yeah. Okay. Alright. I think I hit the prioritize button, so I'm gonna I'm navigating. Alright. If we purchase equipment, modules twenty two five, safe harbor products. So, the other thing I would say is the the the act of safe harboring needs to be done by the entity that is going to own the asset. And so that is that is us. And so, really humbled and appreciate all the installers that have reached out and said, hey. Can I help with safe harboring? Can I go buy some equipment and store it? That's awesome. And that's the mentality that we appreciate. But the short answer is no. You cannot safe harbor. At least we will not be, taking that approach. Any safe harbor material will be us safe harboring the material directly. There's a lot of additional nuance and approvals that we need with our tax funds and others, and that strategy, gets very, very complicated when you enter in a a different entity like an installer. So we are the ones who will be safe harboring the equipment. We will then work with our great distribution partners to distribute as and when the time is right. Alright. K. It's with that. Navigating q and a. Hang with me. Is there a strict requirement on what equipment categories in the bomb need to actually be safe harbor to eradicate? Again, technically speaking, you can safe harbor, you can view you can safe harbor whatever you want. We have taken the view that we are safe harboring inverters and batteries. And by safe harboring those inverters and batteries, that allows you to not have to worry about safe harboring any other equipment. So we safe harbor, that that will allow the project to be ITC eligible. So we've just, again, think it's the, the inverter is the best product, when it comes to tracking. There's monitoring IDs. There's, there's, you know, generally, I think, just a a better, product for, for us to to safe harbor, and that's why we'd be taking that that view. Blah blah blah. Me, Sean, if you, I can take one if you wanna search for the next unanswered one on your side. Okay. Let oh, did I lose it? Okay. Here. Could you show us where in your word database where we can see fiat compliance? So this is a great question. So right now, we don't actually have an indicator for fiat compliance. The best way, to, select components that are fiat compliant is to use the AVLs. So Sean was talking about one of the reasons that, the AVL is going to shrink, you know, come Jan one is because they're going to be removing the modules and the manufacturers that do not meet, foreign entity of concern, compliance. So those AVLs are going to be sort of cleaned up in order to only show sort of FIAC eligible, modules and then within that, there's going to be a subset that can be noted as having domestic content criteria. If that changes and if we introduce a need to be able to distinguish from, an AVL, fiat compliance, and then Domcom compliance, we can add into the sort of design that I just shared, sort of an extra layer. But right now, that's sort of how it's being handled. FIAC is basically being taken on by the financers like LightReach. They are cleaning up their AVL, so you're selecting from things that can be financed and will not be, will not meet that criteria, and then domestic content is sort of a subsection of that. I hope that answered your question. Sean, I don't know if you found one. Yes. I think I got, like, five while you were answering that question. Amazing. Okay. Take it away. So we're we're we're back in business. Could could probably be here all day. Alright. What are the key distinctions between commencing construction before and after 07/04/2026? So it's 07/03/2026. And that's really, you need to have the product. Again, it depends if you're going 5%, or if you're doing the PWT physical work test. So answer slightly, it's nuanced there. But I would say in general, you have to have the product constructed and, you know, basically in a warehouse by by that point in time. So, you can think of the time from now until 07/03/2026. There will be lots of folks working, to build and manufacture, inverters, batteries, or components of inverters or batteries, to ensure that we are in compliance with that. So, that nuance is sort of with us and the OEMs to to manage, not necessarily something that that installers need to to figure out. How will this affect the EPC PPW through LightReach if at all? So yeah. So I think, we're there's not really any sort of changes with our price per watts. I think once if if and when someone is using safe harbor material, that will function similar to if your if folks are familiar with DirectPay, whereby we just remove the cost of that equipment from from the PPW, but the the PPW itself isn't changing. It's just, if you're at $4, there's you would net out the the cost of the safe harbor material from that $4 starter point. I would say, though, that panel prices are going up. If if if folks haven't seen that, like, everyone should be preparing, you know, as you're looking at your margins and your cost tax for 2026, you know, the early. What I have seen and the the data I have seen is, you you all should be preparing for your BOMs to to be more expensive in in 2026, with with everything that's going on as it stands. So, I don't wanna be alarmist, but I'm just saying that as you're thinking about your cost act in 2026, I I do expect it it will be going it will be going up. Alright. I think that all unanswered. I saw a question. I lost it about, like, solar revolution and us being hampered by by all of these things. I would just say that the most resilient bunch of people that I have ever met are the folks that are operating in the solar and storage space. So you cannot, hold us back. I think in general, we all just become far stronger as a result of this. So, we'll just generally say, you know, all of these roadblocks, I think we are confidently jumping over, and, yeah, get getting far stronger as as a as a collective, as a result. So hang in there, continue to navigate, and fight the good fight. I I am reading questions as they come in. I'm gonna so a newbie, is safe harbor only apply to projects that start before July 2026, book kit extended 20? So, again, you can theoretically, you can use safe harbor material whenever you'd like. The main point of you of safe harbor from our perspective is to extend the tax credit beyond when it expires. So right now, if you do not safe harbor, you will the the investment tax credit for third party ownership ends in 2027. So stepping in 2028, 30% tax credit goes away. The whole point of safe harboring is you then extend that 30% tax credit to '28, 29, and 30. Alright. Will you be adding additional racking companies to your AVL? Probably not. I I think we're we're we're always evaluating products that our installers think are really awesome. But I think, we generally feel that we've got, most of the the key racking, manufacturers that installers have asked for already on our ABL. We've been working with those to ensure that they will be FIAQ compliant. At some point, we will have a prepaid lease, in 2026. So hang hang tight. Maybe that's another Aurora Solar webinar we can, get get on the calendar at some point. I don't know if there's any other that you've seen, Mackenzie, that you that are Aurora Solar. I think you just said you just did a marathon. I'm not seeing any other sort of pressing or prioritized ones coming in. And we can always take questions offline as well. So, yes. If there's anything else, from your side, Sean, are are you good to go? Yeah. I think so. Yeah. No. I I just really really appreciate all the engagement and questions. If I if I missed a question or if I didn't get something, please reach out to your relationship manager, or we've got a chat functionality in the LightReach portal, that you can ask questions and and we can sort of support with air cover. But, again, stay tuned. We will have a a Fiat calculator in the LightReach portal. We're doing what we can here, and appreciate all of your, patience, and support, in navigating these these challenges. So I'm really excited about 2026. Despite all of this, hope everyone, has a has a great, great weekend. So thanks for hosting us, Mackenzie and the Aurora team. Really appreciate it. Yeah, Sean, thank you so much. And as you continue to sort of build out this guidance and these calculators, we're gonna try to figure out how to make them easily accessible through the platform as well. We don't wanna have to repeat the amazing work that you're doing, but making sure that those are really accessible to folks when they're sort of in the thick of it. So we're gonna continue to partner to make sure that we can surface these in in the right places and and put the right guardrails in place so you can stay as compliant as possible and stay up to date with all sort of the changing landscape of this. So thanks so much to the LightReach team. Thanks so much for joining us today. And I think that wraps it up. Awesome. Awesome. Great. Bye, everyone. Take care, buddy.