KEYNOTE Navigating a Post-Safe-Harbor World: FEOC's Compliance Challenge
Foreign Entity of Concern compliance is no longer a checkbox, it is reshaping procurement strategy, financing structures, and OEM relationships across the industry.
- What does FEOC compliance require of asset owners and developers, and how far ahead of enforcement is the industry preparing?
- How is regulatory pressure on domestic content reshaping OEM selection, supply chain design, and project economics?
- Which procurement decisions made in 2022 and 2023 are now creating FEOC exposure, and what options do asset owners have?
- How are lenders and tax equity investors treating FEOC risk in project finance, and what disclosures are now standard?
- What does a FEOC compliant domestic supply chain look like at scale, and how far away is the industry from getting there?
What Asset Managers Wish Developers Had Addressed Earlier
How decisions made at the development stage can create operational uncertainties years later.
- Which procurement choices (e.g. warranties, data access rights, LTSA structures, augmentation obligations) are hardest to renegotiate post-COD?
- Finance modelers and legal teams routinely sign off on technical assumptions they don't fully understand, where does that asymmetry show up in the P&L?
- What do investors still misunderstand about the day-to-day cost of running a battery asset, and who is responsible for closing that gap?
- When an asset changes hands, what does a proper technical due diligence look like, and what do buyers routinely miss on state of degradation, maintenance records, and warranty transfers?
The Cost of Compliance, Tariffs, Tier Selection and Project Economics
- Tariffs are a capex line item in every deal. How are developers modelling pass-through provisions into project finance, and how are offtakers responding to higher costs?
- Post-safe-harbor equipment pricing is materially higher. What does a project Internal Rate of Return (IRR) look like now versus 18 months ago, and where is the viability threshold?
- Defaulting to Tier 2 or Tier 3 suppliers to meet Foreign Entities of Concern (FEOC) compliance carries long-term Levelized Cost of Energy (LCOE) risk. How are lenders and independent engineers stress-testing equipment quality assumptions?
- Could domestic manufacturing close the BESS supply gap by 2028, and at what cost premium?
Solar & Storage Finance

California’s Next Chapter: What Will Drive Future Revenue, Reform and Returns?
- Merchant revenues have declined. So what does a bankable California revenue stack actually look like today, and how are lenders adjusting debt sizing against revised forward curves?
- Standalone storage cannot be financed without a swap or toll. How are Resource Adequacy contract rates evolving, and what Internal Rates of Return can developers realistically target in 2026?
- As PPA total contracted capacity has declined in the state over the past year, how can CAISO learn from more dominate offtaker PPA markets such as ERCOT, MISO and PJM?
- Curtailment is eroding solar Levelized Cost of Energy (LCOE) competitiveness. Does co-location solve the economics, and at what cost to the standalone storage business model?
- CAISO interconnection timelines add years to development schedules. What are the cost implications of queue delays, and how are developers pricing interconnection risk into project financing?
Tax Credits in Transition, 48E, Transferability and the Medium Term Future
- Production and Investment Tax Credits dominates deal structuring. Traditional tax equity from major banks has shifted. Some developers face a trade-off between going through regulatory hurdles to gain the tax credit versus importing components and avoiding the tax credit altogether.
- Projects under Section 48E in order to obtain necessary clean energy tax credits face additional scrutiny from tax equity investors, particularly regarding FEOC compliance. What are the capex implications, and how is this reshaping equipment procurement decisions?
- Solar Investment Tax Credits (ITCs) expire after the end of 2027; storage credits run to 2033. So how should developers sequence capital allocation across those two timelines?
- Major investors and banks have paused utility-scale tax equity over FEOC concerns. What does the tax equity supply shortage mean for project debt sizing and developer returns?
Moderator
Solar & Storage Finance

Fireside Chat: Utilities, CCAs and the Southwest Procurement Picture
- California Community Choice Aggregators (CCAs) are among the most active offtakers in the state. How are CCA procurement structures priced, and how do they compare to utility bilateral contracts for developer returns?
- Arizona's removal of its renewable mandate has redirected developer pipelines to California. How is this affecting Power Purchase Agreements (PPA) pricing and bilateral contract negotiations in the state?
- FEOC rules now affect utility network upgrade sourcing. What are the cost and timeline implications for projects dependent on utility infrastructure?
LDES - The Grid Needs More Than Lithium, But Are Investors Ready to Back It? Love this title
- The grid need is clear, but what is the cost of capital for non-lithium storage today versus four-hour lithium-ion? Is the premium justifiable on a levelized cost basis?
- California's CPUC mandates drive the largest LDES procurement pipeline in the US, but policy frameworks are still creating financing barriers. What policy fixes would move the economics?
- Alternative chemistries offer supply chain advantages but carry technology risk. How are lenders stress-testing non-lithium technology assumptions in their underwriting?
- The first credible non-lithium financings will set the template. What combination of offtake, policy support, and capital appetite is needed to get those transactions across the line?
Permitting at Pace — Streamlining Energy Storage Interconnection and Regulatory Approval
- Where are the costliest permitting delays in 2026, and what is the IRR impact of a 12-month approval slippage on a typical utility-scale project?
- FERC fast-tracking large load interconnection requests is creating queue disruption. As hyperscale data centers major power demands supersede other individual developer projects sitting in the interconnection queue, and as network conditions change, how do developers manage financial risk of restudy costs?
- Battery safety standards are fragmented across states, creating permitting unpredictability. How are developers pricing that risk into development budgets?
- How are better-capitalised developers using permitting advantages to improve project economics versus smaller players?
Queue Reform, Grid Modernization and CAISO Interconnection
- What is the fully-loaded cost of CAISO interconnection for a utility-scale storage project in 2026, including network upgrade allocations? How does this compare to ERCOT and PJM?
- Grid Enhancing Technologies can unlock 10-25% additional transmission capacity at a fraction of the cost of new lines. What is blocking adoption, and what would accelerate it?
- California is competing for hyperscaler investment via the GIDAP process. Data centers are exploring islanding to bypass interconnection entirely. What do developers need to do to position projects for that offtake?
- How will AI-assisted interconnection studies reduce study timelines and the cost uncertainty that currently makes project financing harder?
Corporate Offtake and the New PPA Landscape - Hyperscalers, Direct Contracts and Lender Comfort
- What does corporate offtake look like structurally, and how is it priced versus utility bilateral contracts?
- Data center performance requirements, 24/7 availability standards, and underperformance penalties create a fundamentally different contract from utility offtake. What are the development cost implications for project sponsors?
- Lenders treat utility offtake and corporate offtake very differently. What are the specific underwriting requirements for corporate counterparties, and which lenders are becoming comfortable with hyperscaler credit?
Workshop Zone
Hosted Networking Roundtables
Several projects in the battery universe are under financial stress, and tax equity has shifted toward projects with more robust compliance. These four roundtables put developers with live pipeline directly across the table from capital providers with active mandates. Pick the table that matches your situation.
Roundtable 1 — Development Capital & the Bridge to Financial Close
The hardest gap in the market. Developers who have hit NTP but cannot raise project-level financing. Sponsors who expected to contribute 15% equity are now being asked for 35%. Preferred equity providers, bridge lenders, and warehouse facility managers will host.
Roundtable 2 — Recapitalization & Stressed Assets
For developers with portfolios under stress and capital partners not seeing returns. Workout lenders, restructuring advisors, and infrastructure equity firms with appetite for recap transactions will host
Roundtable 3 — Standalone Storage: Floor Structures & Merchant Risk
For developers with standalone storage assets who need financing but will not sign a full toll. Floor and swap product providers, revenue insurance underwriters, and lenders comfortable with hybrid structures will host.
Roundtable 4 — California & CAISO Assets
A geography-specific table for developers with live California pipeline: co-located projects, RA-contracted assets, and VPP plays. Lenders and equity investors with an active CAISO book will host.
Solar & Storage Finance

US Solar & Storage — State of the Market
- Where is new deployment happening and where has it stalled? A market-by-market financial snapshot across CAISO, ERCOT, PJM, and MISO.
- The safe-harbor runway is finite. What does the supply of new compliant projects look like from 2027 onward, and how does scarcity affect asset pricing?
- Load growth continues to accelerate. Where are power prices moving, and what does that mean for merchant revenue assumptions and project IRRs?
The State of the Debt Market, Construction Lending, Private Credit and What Lenders Need to See
- Construction lending has narrowed sharply. Which lenders are still active, at what leverage ratios, and for which revenue structures?
- Private credit providers are facing pressure, including portfolio stress from borrowers. How is this affecting capital availability for renewable and storage projects, and at what cost?
- Hyperscalers have been borrowing enormous sums from the same private credit funds that finance energy projects. Is tech borrowing crowding out renewable capital, and how is this showing up in deal terms?
- What does a bankable project look like in 2026? Revenue structure, compliance status, and interconnection certainty all determine debt sizing. Where is the bar today?
The Load Growth Opportunity — Who Builds the Power, Who Pays & Who Gets There First?
- Load growth is outpacing generation faster than anyone predicted. Data centers, electrification, and industrial demand are driving electricity consumption beyond the grid's current capacity. So who closes the gap, and how fast?
- Data centers want firm power. Batteries are increasingly central to delivering it but reliability requirements go beyond what standard utility offtake is built to meet
- Load growth plays out differently by market. Which of ERCOT, CAISO, PJM, and MISO are best positioned to absorb new generation quickly and where is the mismatch most acute?
- For investors, timing is everything. Projects ready now and opportunities beyond 2028 are being treated as entirely different investment categories. What does the load growth story mean for asset valuations today?
Morning Coffee Break
Solar & Storage Finance

The Revenue Gap, Why Storage Projects Miss Their Financial Models
- Battery self-cannibalization has been one of the more identifiable traits in some grid operator markets. Meanwhile, with over 19GW of BESS in ERCOT as well as 14GW in CAISO, ancillary revenues have compressed. How should forward curves and debt service models be adjusted?
- What are the debt repayment implications when battery operational availability underperforms underwriting assumptions?
- What floor and swap structures are giving lenders enough revenue certainty to size debt?
- Storage accreditation directly determines capacity revenue potential. What Effective Load Carrying Capability (ELCC) outcomes are developers seeing, and how is this affecting investor return models?
VPPs, Residential and C&I Storage - California's Distributed Energy Resources Opportunity
- California has one of the largest VPP programs in the country. How are VPP aggregators monetising distributed batteries, and what does the revenue per unit look like for project sponsors?
- Distribution grid constraints are creating a sub-20MW storage opportunity in California urban markets. How is this financed differently from utility-scale, and what returns are investors seeing?
- When does VPP participation add bankable revenue for lenders, and what contractual structures make it work?
Protecting the Asset, Securing the Capital — Next-Generation Risk Solutions for Solar & Storage
- Rising premiums and coverage exclusions are affecting project bankability. What is the cost impact on project debt sizing and returns in catastrophe-exposed markets like California?
- Tax equity basis step-up insurance, FEOC-related products, and parametric weather instruments are emerging. Which are gaining traction with lenders, and what do they actually cover?
- How are independent engineers and lenders incorporating insurance gap analysis into project underwriting?
Who's Buying What in 2026? M&A, Valuations & the Secondary Market
- Is it a buyer's or seller's market? Where are bid-ask spreads widest, and what is driving valuation divergence between operational assets and development-stage projects?
- How are interest rates, interconnection costs, FEOC compliance status, and supply chain constraints affecting deal pricing and timing?
- Where is transaction activity concentrated, and what IRR are investors underwriting for acquisition today versus 24 months ago?
Solar & Storage Finance

Shark Tank
- Quick-fire presentations from project developers in front of a panel of capital provider judges, detailing the financing, investment, and acquisition opportunities they are currently seeking in the US market.
- Developers will make their case directly to a panel of capital provider judges, who will respond with their current investment appetite across asset classes, transaction sizes, and power markets.
Life After the Solar ITC, Financing Projects When the Subsidy Is Gone
- With solar ITCs and storage credits expiring in the shorter to medium term, for hybrid projects, can storage ITC be structured to finance the solar component, and how are lenders treating this?
- Without ITC, what PPA rates do offtakers need to offer to make a solar project viable? Are any utilities or hyperscalers already signalling willingness to move on pricing?
- Post-ITC projects have more freedom from FEOC sourcing requirements but still face anti-dumping, counterveiling duties (AD/CVD) and cybersecurity obligations. How does the cost structure change, and are project economics better or worse?
- The industry has long depended on tax credits. Is post-2027 solar the moment it must stand on its own economics, and what does that project look like?

