U.S. power markets are in a period of unusually strong, and increasingly uneven, change as data centers accelerate demand while generation, transmission, and market structures struggle to keep pace. PJM is confronting capacity scarcity, MISO remains adequate but warns of tightening, ERCOT’s wrestling with enormous and uncertain large load forecasts, while CAISO's rapid renewable and storage buildout and SPP's Western expansion offer different models for managing growth. The geopolitical landscape, FERC rulings, shuttered plants coming back online, and the push for oil and gas expansion further complicate the picture. This session will discuss the state of the power markets, pricing curves, project valuations, and the economic useful life of projects today.

• Where are power and capacity prices headed, and which markets have the strongest fundamentals? How do load, natural gas prices, extreme weather, and other factors affect forward curves today?
• Distinguishing actionable demand from speculative requests: what happens to investment decisions if forecasts prove too high? What about volatility, policy changes, risk, and valuations across ERCOT, PJM, MISO, SPP, CAISO, and other regions? How are non-shuttered coal plants affecting prices?
• Are regional structures producing the right investment signals, and how are market signals affecting project viability? PJM's capacity auctions reflected severe supply/demand pressure: what’s the fix?
• Which regional reforms are materially changing the opportunity for renewables and storage? How are ERCOT's evolving large load and market rules, MISO's resource adequacy efforts, CAISO's growing reliance on storage, and SPP's expansion into the Western Interconnection affecting congestion, curtailment, basis risk, merchant revenues, and financeability?
• Can stronger energy, capacity, REC and PPA prices make more projects viable on market economics, and which states and regions offer the clearest path to financeable post-subsidy projects?

Sponsor equity is entering a new phase as investors reassess platforms, projects, and operating assets against capital requirements, changing tax credit economics, execution risk, and an increasingly valuable need for power. While distressed assets and platforms are on the rise and consolidation is creating opportunities for well-capitalized buyers, operating history is providing a clearer test for realized returns. This session will examine where equity capital is flowing, what investors are willing to pay for, and how return expectations are changing for 2027 and beyond.

• Capital flow: what is the current activity in the markets, cost of capital and debt, and what’s getting funded or passed over? Do recent transactions signal real confidence or selective optimism?
• What returns are required today? How are interest rates, inflation, power forecasts, commodities, or other factors affecting rates, cost of capital, and acceptable risk/return profiles?
• Is consolidation creating a new capital formation opportunity? As smaller/undercapitalized platforms struggle to execute, are buyers becoming more aggressive? Do sponsor safe harbor strategies align with investor assessments? Comedy and investing: strategies on timing?
• Do investors put greater weight on execution and operating performance today? Is queue position, FEOC compliance, construction capacity, or realized revenues changing underwriting?
• How are investors positioning portfolios for the post-tax credit market? What percentage is in renewables/storage versus data centers or adjacent opportunities? What does that competition mean for renewable sponsor equity? What about geography and investment size?

The lending market has moved from broad policy uncertainty toward a more execution focused question: what separates the deals that get financed from those that no longer pencil? Banks remain active, but tax credit qualification, FEOC, PPA structures, interconnection and construction risk, higher capital costs, and increasingly complex revenue models are reshaping underwriting, debt sizing, pricing, and lender appetite across renewables and storage. In this session, top lenders will share insights into what gets funded today, the risk profiles that match their appetites, and where the market is heading.

• What’s the appetite to finance new projects in 2027, what are the current sources of capital in the markets, and how are banks looking at political and tariff risk today vs. last year?
• How are lenders weighing safe harbor status, sponsor strength, queue position, equipment procurement, PPAs, merchant exposure, construction risk, and project economics? Are lenders underwriting generation tied to hyperscalers, and how are they assessing the risks?
• Are banks comfortable with FEOC risk, what protections or documentation are required, and do some projects remain sidelined? Will financing shift toward technologies with tax credits?
• Underwriting today: How much merchant exposure is acceptable, how are shorter or hub-settled PPAs and basis risk treated, and do projects with less predictable contracted cash flows require?
• What are lenders seeing in spreads, leverage, debt sizing and refinancing risk, and could changing interest rates, inflation, private credit conditions, or bank capacity materially expand or constrain what’s financeable? What does lending look like for the next 3-5 years?

The industry is shifting from navigating policy uncertainty to executing projects under a demanding set of rules, economics, timelines, and capital constraints. As safe-harbored pipelines move to construction, developers prepare for projects with stiff economics and make increasingly disciplined choices for interconnection, capital allocation, equipment, FEOC compliance, offtake, and which projects deserve to remain in the pipeline. This session focuses on the project execution landscape and considers how planning and decision-making is changing for developers in 2027 and beyond.

• What does the development pipeline look like for the next 3 to 5 years? Will most safe harbored projects be executed? How workable is the final FEOC guidance, and how are the risks mitigated?
• How do developers prepare for post-tax credit deals while executing today's projects? How much do inflation, tariffs, permitting, transmission constraints, and workforce limitations affect viability? Do other new rules affect planning, like the inverter ban? How are smaller developers keeping up?
• Is the new landscape forcing developers to build smaller, more disciplined pipelines? Are sponsors investing more in local market expertise? Is repower poised to grow? What’s financeable today?
• How are developers making go/no-go decisions around PPA pricing and tenor, merchant exposure, interconnection, procurement, FEOC, construction costs, tax credits, and debt and equity deals?
• Large load: are co-location, behind-the-meter, storage as capacity, and new offtake structures creating executable opportunities? What structures are being used?

Sponsors now have a broad set of options for converting tax benefits into project capital, but choosing the right tax credit monetization strategy can be complex: from traditional TE, pref eq, and direct TC transfers to TE or pref eq paired with credit sales, t-flips, and other hybrids. These structures increasingly coexist within the same capital stack, making the key question not which structure wins, but which combination provides the best balance of proceeds, certainty, cost, timing, risk allocation, and sponsor flexibility for a particular project. How are TE, pref eq, and sales used in the market, in what proportions, and how can each best support specific assets and deals?

• How should sponsors compare traditional TE, pref eq, and credit sales? What are the relative costs, proceeds, execution certainty, timing, complexity, sponsor control, and risk allocations? Which structures are best suited to what assets and credit profiles? What about hybrids?
• Pref eq can leave sponsors responsible for finding a credit buyer, while TE shifts that to the investor: how do sponsors value that difference? When does pref eq paired with credit sales outperform TE?
• When is a vanilla tax credit sale best, and when does traditional TE provide value beyond monetizing the credit? How is pricing being weighed against depreciation benefits, capital needs, counterparty strength, recapture exposure, indemnities, guarantees, and the ability to transfer execution risk?
• How are FEOC and other qualification risks changing each structure’s economics? What diligence will TE investors, pref eq providers and credit buyers require? Who bears recapture risk, and how much can tax insurance or an investment-grade indemnity improve pricing and execution?
• Are hybrid structures the new normal? When does it make sense to combine TE, pref eq, credit transfers and debt rather than select a single monetization strategy? Do more financing tools produce better economics or simply add counterparties, diligence, and closing complexity?

As interconnection, permitting, equipment, and development timelines lengthen, projects require more and earlier capital, often years before construction or permanent financing. Meanwhile, investors have become more selective in committing funding amid greater execution uncertainty. This session will examine how developers attract early to mid-stage capital, structure it around uncertain milestones, and manage deployment so projects remain adequately funded through an increasingly long and expensive road to construction.

• Where does early to mid-stage capital come from today, and what’s the cost? How are debt, development equity, pref eq, co-development, land deals, Greenbanks, green bonds, regional lenders, or other sources filling the gap? Are inflation, tariffs, and interest rates a drag on deals?
• What does it take to attract capital early in a lifecycle? How do investors evaluate sponsor strength, market expertise, interconnection position, site control, permitting, offtake prospects, tax credit eligibility, and the probability that a project reaches construction? Does this differ across regions?
• How do longer interconnection and development timelines change the amount and structure of capital? As queue deposits, credit support, and other expenditures increase, are investors staging commitments around milestones or demanding greater control and returns?
• How is capital best managed when timelines and economics can change materially before NTP? What structures, strategies, milestone-based funding, contingency reserves, and contractual protections can prevent projects from consuming too much capital while preserving optionality?
• How can smaller developers continue to compete? Are partnerships, portfolio financing, strategic capital, project sales, or earlier M&A necessary to carry projects to NTP? If a delay happens, how do developers decide to recapitalize, sell, partner, or abandon a project?

As TE and TC transfer transactions move into a more complex compliance environment, diligence is becoming increasingly important to both deal execution and long-term credit value. 48E qualification, FEOC, supply documentation, sponsor creditworthiness, and execution risk are expanding what buyers and investors need to verify, while tax insurance, guarantees, indemnities, and other protections are evolving to keep transactions financeable.

• What is standard diligence for TE, credit sales, and hybrid deals today? How do investors and buyers approach sponsor strength, project fundamentals, eligibility, technical assumptions, construction risk, documentation, and 3rd party verification? Where are requirements most demanding?
• How is FEOC changing the diligence process? What must parties establish around foreign influenced entities, ownership, debt structures, and material assistance? What uncertainty makes investors or buyers uncomfortable, and what pitfalls are avoidable? Are all parties clear-eyed and reasonable?
• Everyone wants certainty: how are underlying risks allocated? Which exposures do sponsors retain through indemnities, guarantees or parent support, what protections do investors and buyers require, and what solutions exist for sponsors without large balance sheets?
• What role is tax insurance playing in getting difficult transactions across the finish line? Which FEOC, qualification, recapture, and other tax risks are insurable, how much independent diligence do insurers require, and when can insurance expand the universe of financeable or saleable credits?
• Will today's diligence and risk protections hold up over the life of the transaction? How should parties address change-in-law risk, post-closing compliance, underperformance, foreclosure or ownership changes? What about recapture and other issues that may emerge down the road?

As portfolios mature, stakeholders have more operating history to test whether generation, revenues, availability, costs, and asset life match original underwriting assumptions. With continued capital formation increasingly dependent on assets performing as promised, operating data is becoming a more important input into financing, valuation, portfolio acquisitions, and the assumptions used to underwrite the next generation of assets. This session will discuss how performance data can be used to optimize both the value of existing assets and assumptions for new deals.

• Are operating assets performing as underwritten, and if not, why? How does actual generation, availability, degradation, operating costs and revenues compare with base cases across asset types?
• How does performance data affect financing and valuation? Are lenders and investors adjusting P50/P99 assumptions, debt sizing, coverage ratios, return requirements, useful-life assumptions or acquisition pricing? Is peak performance possible? When is repower effective?
• What drives underperformance: equipment and design, curtailment, congestion, basis risk, weather, market changes, O&M, or something else? What can be identified and mitigated early?
• Storage: how are revenues, cycling, degradation, availability, operating costs, and market performance comparing with base case? Is operating history changing underwriting, debt sizing, valuations, and return expectations? What pre- and post-construction modeling is helpful?
• Turning operating experience into better performing investments: where can asset management, monitoring, analytics, AI, O&M strategies, repowering, or storage additions improve existing assets? How should lessons flow into future PPAs, financing structures, design and investment models?

* Panel description will be updated as the final FEOC guidance becomes known.

Procurement is now inseparable from tax credit qualification: FEOC final guidance delineates a central diligence, procurement, and financeability issue for the next generation of renewable and storage projects. FEOC compliance includes ownership, financing, and contractual control issues, not simply equipment sourcing. Specified Foreign Entity (SFE) and Foreign Influenced Entity (FIE) rules affect eligibility based on ownership thresholds, debt relationships, appointment rights, and contractual arrangements that give SFEs effective control over a project, making entity structure and counterparty agreements critical areas of diligence for sponsors, lenders, TE investors, and credit buyers.

• Final guidance: does any uncertainty remain? How should sponsors assess direct and indirect ownership, partnership structures, board or officer appointment rights, and affiliated entities?
• How do debt and financing relationships affect FEOC status? The statute includes a 15% threshold for debt issued to SFEs or FIEs: how should sponsors evaluate existing and proposed financing before capital enters? When can ownership changes happen?
• What constitutes “effective control” without significant ownership? Which licensing, O&M, equipment, technology, data access, IP, or other contractual rights with a foreign counterparty could jeopardize eligibility? Is the Treasury's guidance clear and usable?
• How should agreements be structured to avoid unintended effective control? What provisions should developers revisit in licenses, O&M agreements, contracts, joint ventures, debt documents, and other long-term arrangements? How does this relate to MACR calculations?
• What diligence will financiers require vis-a-vis ownership and control? How should TE investors, credit buyers, lenders, and insurers evaluate structures, debt, contractual rights, representations, indemnities, and ongoing compliance? Who ultimately bears the risk if FEOC status changes?

Traditional project finance structures are being tested by shorter PPAs, greater merchant and basis exposure, changing tax credit economics, and new large load customers with different needs around speed, reliability, and flexibility. As a result, developers, lenders, investors, and offtakers are increasingly using bespoke financing structures and contract provisions to allocate risks that no longer fit neatly within conventional renewable transactions.

• Which innovative financing structures are getting deals done? Where are preferred equity, bridge structures, private credit, revenue sharing, portfolio financings, hedges, and other bespoke capital solutions filling gaps that traditional project finance cannot?
• How are shorter PPAs changing financing structures? What merchant tail will lenders accept, how are hub-settled PPAs and basis risk being addressed? Which reserves, guarantees, or protections can make less-contracted revenues bankable?
• How are contracts adapting to tax credit and policy uncertainty? How are contingent pricing, change-in-law, or other mechanisms being used, and what triggers are common?
• Are data centers creating a new category of bespoke financing? How do lenders approach behind-the-meter, co-location, phased development, multiple generation technologies, project-on-project risk, hyperscaler creditworthiness, and the possibility that projected load never materializes?
• Where is financial innovation solving real risk, and where is it simply moving it elsewhere? How are lenders and investors diligencing complex structures, forward curves and load assumptions, and what protections support financing without making projects prohibitively expensive?

PPA markets are entering a new phase, as rising demand collides with changing development costs, tax credit economics, contract tenors, and merchant and basis exposure. Around 40-45 GW of corporate offtake deals signed during the blockbuster 2024-2025 cycles are scheduled to achieve commercial operation, but what’s next? This session will discuss how developers, buyers, and lenders can create structures that balance clean energy objectives and financeability, including where PPA pricing is headed beyond today's safe harbored pipeline, how data center buyers are changing the definition of a valuable offtake agreement, and what deal provisions and negotiations look like today.

• How much of the higher capital, equipment, interconnection, and development costs must flow through to offtakers? How does offtaker creditworthiness affect underwriting criteria?
• Shorter PPAs: What’s the mismatch between what buyers want and what lenders can finance? How are 5-10-year contracts, merchant tails, extensions, refinancing risk, and residual asset value being underwritten? What bridges the gap between offtaker flexibility and long-term revenue certainty?
• When do physical PPAs, vPPAs, hedges, cross-collateralization, or other structures provide benefits? What about green tariffs, interest rates, or corporate tax rates? What’s going on in RECs?
• How are parties allocating the risks that increasingly sit outside the traditional fixed-price PPA? Who takes basis and congestion, curtailment, negative pricing, change-in-law, and merchant tail? Are hub-settled PPAs, hedges, floors, collars, contingent pricing or other bespoke provisions common?
• Post-2030 offtake: how might PPAs, RECs, and other structures adapt? With corporate procurement at record capacity levels but fewer individual buyers participating, what can broaden the market?

Storage has a longer tax credit runway and growing strategic value as load growth and renewable penetration increase the need for flexible, dispatchable capacity, but financing remains highly dependent on market, contract structure, and operating assumptions. As the sector develops a deeper performance history, lenders and investors are moving beyond deployment forecasts to ask whether revenue stacks, degradation assumptions, equipment strategies, and actual operating results can support durable project economics. The future of storage hinges on aligning technical, financial, and regulatory realities to unlock long-term value, including:

• What does a bankable storage deal look like now? How much revenue certainty is necessary to support leverage? How are physical and virtual tolls, tiered-revenue sharing, ESCAs, or other bespoke agreements working, and how are lenders underwriting all of these?
• Revenue: how do arbitrage, capacity, ancillary services, congestion management, demand response, and data center-related compare to one another? Are multi-revenue deals more bankable or just more complex, and is there financing for multiple less certain revenue streams?
• What percentage of deals are standalone vs. co-located, and how are separate financings for co-located assets working? Are data centers creating more financeable long-term revenue models?
• How much have FEOC and Executive Order 14420 changed equipment strategy? Is storage attracting more TE and transfer capital, and how are domestic content, effective control and MACR handled?
• How do actual revenues, cycling, degradation, availability, and O&M costs compare with base cases? Is performance history changing debt sizing, valuations, warranties, and investor expectations? How does this change across power markets? Is better analytics an answer? Is merchant dead?

As safe-harbored wind and solar pipelines are built out, the industry is beginning to confront a fundamental shift from tax credit supported economics toward projects that must stand on power market fundamentals. The transition will require more than replacing tax equity: developers, investors, lenders, and offtakers will need to reset PPA pricing, return expectations, capital structures, and development strategies to reflect higher upfront capital needs, longer timelines, and the true unsubsidized cost of new generation.

• What does the capital stack look like now, and how will it change when TE disappears? Will projects require more sponsor equity, pref eq, private capital or debt? Where and at what stage? How much leverage is ok, and what will make projects too expensive or risky?
• How should capital be allocated between today's qualified pipeline and tomorrow's market driven projects? As safe harbor phases out, which regions and opportunities deserve capital? When can sponsors begin projects without subsidies given higher capital requirements? Pre-NTP costs?
• How much must PPA and power prices rise, equipment and soft costs decline, and which markets have the strongest fundamentals to support subsidy-free development?
• How are valuations, rates, returns, and cost-of-capital assumptions changing? What about equity, preferred/mezzanine capital, senior debt, bridge loans, and project bonds?
• Are infrastructure funds, revenue-sharing, offtake-backed securitizations, or other alternatives gaining traction? As commitments become non-refundable, are more equity, surety facilities, partnerships, or flexible exits needed? When is a project sufficiently de-risked for lenders?
• Can offtakers close the gap with high PPA prices, longer contracts, or different risk allocations? Should contracts use price adjustments if tax incentives return or project economics change?

Procurement is a critical link between tax credit eligibility, FEOC compliance, project economics, and execution as developers race to deploy qualified pipelines. Treasury and IRS PFE material assistance guidance on Sections 45Y, 48E, and similar restrictions on Section 45X manufacturing credits, along with domestic content adders, are colliding with global supply chain realities. Determining what’s compliant, available, financeable, and cost effective requires a shift from understanding FEOC conceptually to building procurement documentation, contracting, and diligence processes that demonstrate compliance and give lenders, tax equity investors, and credit buyers the certainty to transact.

• What does a financeable procurement strategy look like today? What’s the balance of cost, availability, bankability, and tax credit value, and when does equipment sourcing need to be locked down? How are domestic content and FEOC handled together?
• MACR calculations: Is the Treasury's cost ratio workable? What certifications, cost information, traceability, and recordkeeping will sponsors need to substantiate compliance?
• What’s happening in manufacturing investment: Which parts of domestic supply are successfully scaling, where do foreign dependencies remain, and is additional capacity justifiable today? How does the Trump administration’s manufacturing goals square with its energy policy writ large?
• How do Section 232, AD/CVD exposure, tariffs, wars, and trade uncertainty affect costs, contracting, and supplier diversification? How can sponsors handle long-lead equipment, supplier relationships, and pipeline allocation when projects may span different guidance regimes?
• How should contracts allocate risk when rules and supply chains can still change? Who bears what risk if equipment fails to qualify? Are substitution rights, supplier representations, indemnities, guarantees, change-in-law provisions, or tax insurance necessary?