by: David Riester

 

Appendix 

 

The impact-estimating work above requires methodological choices that bear explaining, for those who are interested in understanding at a deeper level: 

Reference project details. For the PV array, we use a base case cost of $1.06/Wdc, which is Wood Mackenzie utility-scale pricing index as of Q2.  For the battery storage, we use a 4-hour configuration that cost $300/kWh. The assumed ITC basis is $1.57/Wac, which is a ~15% step up to costs, with ~91% of costs ITC eligible. The ITC is modeled at 30% in all cases. The tax equity proceeds assume a straight sale of the tax credit at $0.95 cents on the dollar. The ITC is held flat across scenarios to isolate the variable being tested.  

Other modeling notes. Tariffs and FEOC are stacked sequentially so there’s no double count. The tariff bogey is the post-232 after-tax value. That does not necessarily address FEOC restrictions, however, so FEOC compliance costs are studied incremental to the post-232 after-tax value. The “totals” in the table use $0.15/Wac from the FEOC impact range. 

For the interest rate measurement, we simply add 100 bps to the debt interest rates, and 100 bps to the equity target from NTP forward, and do not attempt to pick up pre-construction cost-of-capital increases. Though very real, the latter are captured in the “Project Assassination” analysis.  

For capacity the same clearing price ($300/MW-day) is held constant to isolate the impact of accreditation values.  The “how it should/could work” case holds 90% of today’s accreditation for storage (~50%) flat for 5 years, with the revenues included in debt sizing; the “how it is now” case uses variable accreditation values at PJM’s published curve and those revenues excluded from debt sizing. 

The “Project Assassination” analysis has three layers. 1. Delay: the NPV cost of a six-month federal stall (added LC costs, equity carry on development expenditures) on the reference project returns $0.019/w; multiply that times the one-third of the early-stage pipeline Wood Mackenzie says is now under heightened federal review: $0.006/w. 2. Risk premium: the extra return a group like Segue requires on development capital when a project carries a federal nexus (using extra 0.5x in MOIC target) converted to value: $0.026/w. 3.  “Hazard rate” (amortizing dead money): ~32 GW of named projects halted, revoked, bought out, or killed by federal action since January 2025, against the ~85–90 GW of solar, wind, and storage that reached commercial operation over the same window – a ~35% hazard rate – applied to the control case development margin of 0.151/Wac = $0.053/Wac. 

Presenting “apples-to-apples”. Some of the hits/impacts are specific to solar, some to storage, and some to both. To preserve a basis for comparison, all impact is expressed in terms of the full system’s AC capacity (125MWac), so $/125MWac. This lands a bit awkwardly in a couple spots (for example you can’t quickly eyeball the ITC delta, because it hits the PV array only, yet the change is expressed in terms of full system), but the alternative is numbers that can’t be properly contextualized or having two separate control projects (one for PV, one for BESS), which would be hard to follow.   

Project “enterprise value” (e.g. interest rate impact being 5.7% of enterprise value) uses control case [costs] + [margin] of ~$208m in the denominator.