Texas Clean Energy 2026

While record imports in 2025 gave developers supply to safe harbor a spate of projects, tariffs somewhat leveled, and domestic content (DC) charts and percentages are largely workable, the industry is barreling toward a new phase of supply chain complexity. Foreign Entity of Concern (FEOC) restrictions, uncertainty around guidance, compliance verification, and risk allocation are driving new diligence requirements and contractual considerations. Together tariffs, FEOC, DC, and TX’s LoneStar Protection Act from a Venn diagram reshaping procurement strategy, limiting supply, and adding new risks. This session will explore how stakeholders thread the needle on these rules, managing cost and risks, and structuring projects to remain viable.

• Will FEOC raise costs and slow planning, and does waiting for final guidance risk losing the DC bonus? How do sponsors ensure procurement certainty, and what kinds of structuring might help? How important are relationships in this?
• Hanging your hat on tariffs: Have tariffs stabilized, and what’s the added cost today? Is anyone looking for an IEEPA refund? Treasury engagement with stakeholders: Are the discussions constructive, and is final guidance aligning with stakeholder fact patterns?
• The LoneStar Protection Act already prohibits electric grid equipment contracting with entities from China, Russia, Iran, and North Korea: How much more complexity does FEOC add for Texas projects? Do these two pieces of legislation align, or are there gaps?
• Project level restrictions vs taxpayer level restrictions: What’s clear? Is FEOC guidance on labor and material sourcing complete enough to dispel uncertainty? Material assistance, continuous construction, PFE ambiguities: what challenges do these create?
• Are FEOC compliant equipment suppliers charging more, and where will costs ultimately land? How many projects have become uneconomic due to FEOC, and are there remedies?
• 3rd party verification: Are investors, credit buyers, or other parties looking to 3^rd parties for valuation? What documentation do sponsors or EPCs need to provide? Who’s wearing recapture risk? How limited is US made supply given manufacturing gains?