2022 Vol. 106 No. 5

24 SEPTEMBER / OCTOBER 2022 LENDING / CREDIT For Community Banks, the Sun Also Rises Solar tax credit investments now more accessible Joshua C. Miller CEO KeyState Renewables jmiller@key-state.com KeyState Renewables is a subsidiary of The KeyState Companies, a Diamond Associate Member of the Indiana Bankers Association. For more than a decade, large financial institutions like U.S. Bank, NA, and Wells Fargo, joined by Fortune 500 giants like Apple and Google, have been the dominant players in solar investment tax credits (ITCs). Driven by federal incentives, these companies have provided funding for the largest solar projects in the country, collecting healthy returns while raising their corporate profiles as environmental/social/ governance (ESG) leaders. The benefits of solar ITCs are hard to ignore. Tax credit investors funding renewable energy projects can significantly offset their federal tax liability and recognize a meaningful annual GAAP earnings benefit. From 2005 to 2020, renewable energy tax credits fueled the explosive growth of solar and wind power production nearly 18-fold. The recently passed Inflation Reduction Act is a transformational bill with provisions that will entice large numbers of midsize businesses and community banks to deploy capital into renewable energy projects across the U.S. It extends solar ITCs for at least 10 more years (until greenhouse gas emissions are reduced by 70%) and retroactively increases the ITC from 26% to 30%, effective Jan. 1, 2022. This extension and expansion of ITCs, along with other meaningful incentives included in the bill, will result in a significant increase in renewable energy projects being developed and constructed over the next decade. Community banks are the logical source of financing for solar ITCs and traditional loans in response to this expected flood of midsize renewable projects. Solar ITCs have a notably better return profile than other types of tax credit investments commonly made by banks. Solar ITCs and the accelerated depreciation associated with a solar power project are fully recognized once it is built and begins producing power. This is quite different from other tax credit investments, such as new markets tax credits, low-income housing tax credits and historic rehabilitation tax credits, through which credits are recognized over the holding period of the investment (5, 7, 10 or 15 years). Like other tax equity investments, solar tax equity investments require complex deal structures, specialized project diligence and underwriting, and active ongoing monitoring. Specialty investment management firms provide support to community banks hoping to make solar tax credit (i.e., “solar tax equity”) investments by syndicating the investments across small groups of community banks. Without support, community banks may struggle to consistently identify suitable solar project investment opportunities built by qualified solar development partners. Not all solar projects are created equally, and it is critical for a community bank to properly evaluate all aspects of a solar tax equity investment. Investment in particular types of solar projects including utility, C&I, municipal and community solar projects can provide stable and predictable returns. A community bank investor, however, should perform considerable due

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