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THE SUN IS SETTING ON �FEDERAL SOLAR INCENTIVES

FIERCE URGENCY OF NOW

Welcome to our webinar!

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TABLE OF AGENDA

  • Presenters
  • Interfaith Solar Campaign: Inspiring a Movement
  • CollectiveSun: Helping Houses of Worship Go Solar
  • Policy Changes Affecting Solar for Houses of Worship
  • The Path Forward
  • Q&A

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INTERFAITH POWER & LIGHT CALIFORNIA

Gregory Stevens

Northern California

CIPL Director

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  • Former Baptist preacher, labor organizer, and interfaith activist now directing climate change responses in Northern California.
  • Holds a BA in Religion and Gender Studies, a MDiv, and a MA in Anthropology.
  • As a Climate Change Champion he strengthens multi-religious efforts against climate change with a blend of creativity and activism.
  • Inspired by childhood in Florida, passionately advocates for planetary healing.
  • When not saving the planet, you can find him in overstuffed used bookstores, taking in the redwood trees, and learning from documentaries.

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GREEN THE CHURCH

Rev. Dr. Ambrose �F. Carroll

Green The Church �Founder

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  • Senior pastor at Renewal Worship Center Oakland, CA, and one of the nation’s premiere Practical Theologians.
  • Holds a BA from Florida Memorial College in Miami, FL, an MDiv from Morehouse School of Religion in Atlanta, GA, a DMin from United Theological Seminary in Dayton Ohio, and an MBA from Golden Gate University in San Francisco.
  • Has served as Pastor in various churches in California and Colorado.
  • Created the national campaign to “Green The Church” with a national nonprofit charged to educate the Black Church and lead in the creation of sustainable programs to undergird the work of creating green and efficient church buildings.

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PRESENTERS

Lou Stagnitto

Interfaith Solar Campaign

  • Brings over 20 years of experience from the Healthcare sector
  • Board Chairman of the Quest Center for Integrative Health
  • Enjoys cultivating a healthy lifestyle with his garden filled with nutritious produce & vibrant flowers

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Lee Barken

Chief Community Officer, CollectiveSun

  • CPA, LEED-AP, an active board member of Cleantech San Diego, and on the Impact Investment Committee at Catalyst of San Diego.
  • Bachelor of Science Degree in accounting from San Diego State University.

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INTERFAITH SOLAR CAMPAIGN

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Inspiring a Movement

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HELPING FAITH COMMUNITIES GO SOLAR

  • Demonstrating how
  • Connecting with resources that make solar happen
  • Partnering with you through the process

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WHO IS COLLECTIVESUN?

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MAKING SOLAR A REALITY FOR HOUSES OF WORSHIP

POWERING THE MISSION

  • Over a decade ago, we recognized that nonprofits didn’t have easy access to the myriad benefits that come with clean renewable energy.
  • So we started CollectiveSun!

WWW.COLLECTIVESUN.COM | INFO@COLLECTIVESUN.COM | 888.980.CSUN (2786) 

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  • We streamline the process to support houses of worship in going solar.

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  • We have supported over 200 nonprofit organizations on their solar journey.

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  • We have been the industry’s solar funding experts for over a decade.

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  • Active in 25 states & counting.

TEMPLE BETH DAVID

WESTWOOD, MASSACHUSETTS

NEW MILFORD UMC

NEW MILFORD, CONNECTICUT

GOOD SAMARITAN EPSICOPAL CHURCH

SAN DIEGO, CALIFORNIA

SUNBURY BIBLE CHURCH

NORTHUMBERLAND, PENNSYLVANIA

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The information presented today is for educational purposes only and should not be construed as tax or legal advice. Please consult your tax advisor or legal professional for personalized guidance.

DISCLAIMER

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ONE BIG BEAUTIFUL BILL (OB3)

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  • READ THE BILL — see Sections 70512 (p.181) and 70513 (p.199)
  • Enacted July 4, 2025 via reconciliation
  • Creates a major sense of urgency to START NOW

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GOOD NEWS

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  • Solar ITC (48E) survives through 12/31/27 Placed in Service (or later if BOC by 7/4/26)
  • No changes: Battery Storage (48E) survives through 2032+
  • No changes: Bonus Adders remain in place as long as ITC is in place
  • No changes: Direct Pay remains in place as long as ITC is in place

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NOT-SO-GOOD NEWS

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  • Foreign Entity of Concern (FEOC) ITC disqualification gauntlet
  • 7/4/26 Beginning of Construction or 12/31/27 Placed in Service dates will be here soon!
  • 12/31/25 Beginning of Construction for FEOC is even sooner!

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FOREIGN ENTITY OF CONCERN (FEOC), P. 182

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“National Security Threats” per OB3: Foreign Adversaries, Foreign Terrorist Organizations, other lists

  • People’s Republic of China (includes Hong Kong)
  • Islamic Republic of Iran
  • Russian Federation
  • Democratic People’s Republic of Korea (North Korea)
  • Everybody else

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TWO TESTS FOR FEOC

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Two Tests = Taxpayer Identity, Supply Chain Sourcing

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  1. Taxpayer Identity: Who is claiming the ITC? (“Prohibited Foreign Entity” - PFE)
    • Ownership (“Specified Foreign Entity” - SFE)
    • Control (“Foreign Influenced Entity” - FIE)

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  • Supply Chain Sourcing: Is my equipment made by a PFE? (“Material Assistance”)
    • Material Assistance Cost Ratio (MACR)

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FEOC

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FEOC Compliance Quiz: Solar Manufacturer

  • Physically located in USA
  • Incorporates many US components
  • Owned by Chinese company

Does not meet FEOC compliance

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Does meet FEOC compliance

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FEOC

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FEOC Compliance Quiz: Solar Manufacturer

  • Physically located in USA
  • Incorporates some US components
  • Owned by Chinese company

Does not meet FEOC compliance

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Does meet FEOC compliance

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WHERE DO WE GO FROM HERE?

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START NOW: Two Safe Harbors

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  • ITC
    • Beginning of construction on/before July 4, 2026
    • Safe Harbor ITC for 4 years
  • FEOC
    • Beginning of construction on/before December 31, 2025
    • Safe Harbor from FEOC (FEOC compliance not needed)

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BEGINNING OF CONSTRUCTION - HISTORICAL RULES

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  • IRS Notices 2013-29 and 2018-59 + others
    • Physical work test
    • 5% test

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PHYSICAL WORK TEST

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  • Focus is on nature of work, not amount of work or cost
  • Must be “Significant”
    • Manufacture components (i.e. transformers, wind turbines)
    • Install racking/support structures
    • Pouring concrete
    • Mounting solar modules
  • “Preliminary Activities” do not count!
    • Planning/admin/legal
    • Getting permits
    • Purchasing equipment (unless custom)
    • Site prep (clearing/leveling/removing items)

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5% TEST

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  • Pay or incur 5% of the total project cost
    • Pay (cash basis)
    • Incur (accrual basis) - liability must be fixed/known + economic performance
    • Exceptions: 3.5 month rule / look-through rule
  • Eligible ITC costs only!
  • Shoot for 7%-10%+

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Project cost = $100,000

You spend $5,000 = 5%

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Then project cost increases to $101,000

The $5,000 is now 4.95% FAIL

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BEGINNING OF CONSTRUCTION

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  • Additional Considerations
    • Binding written contract
    • Continuity test
    • Facts and circumstances
    • Record keeping / documentation

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EXECUTIVE ORDER

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READ THE EO, issued July 7, 2025

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  • ITC: “Within 45 days... ensure that policies concerning the “beginning of construction” are not circumvented, including by preventing the artificial acceleration or manipulation of eligibility and by restricting the use of broad safe harbors unless a substantial portion of a subject facility has been built.”

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  • FEOC: “Within 45 days… the Secretary of the Treasury shall take prompt action as the Secretary of the Treasury deems appropriate and consistent with applicable law to implement the enhanced Foreign Entity of Concern restrictions in the One Big Beautiful Bill Act.”

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IN CONCLUSION …

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START NOW

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IF YOU BEGIN CONSTRUCTION BETWEEN NOW AND 12/31/25

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  • 4 years to place in service (12/31/29)
  • FEOC “Material Assistance” rules do not apply

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IF YOU BEGIN CONSTRUCTION BETWEEN 1/1/26 AND 7/4/26

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  • 4 years to place in service (12/31/30)
  • FEOC “Material Assistance” rules do apply

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IF YOU BEGIN CONSTRUCTION AFTER 7/4/26

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  • Must place in service by 12/31/27
  • FEOC “Material Assistance” rules do apply

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IN CASE YOU MISSED IT…

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START NOW

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SOLUTIONS

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COLLECTIVESUN SOLAR FINANCING OPTIONS

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  • Interest rates based on community impact, not just credit score
  • No payments during construction; no collateral required beyond solar equipment
  • Direct Pay Tax Filing Service
  • No prepayment penalties
  • Installer vetting
  • 20-year agreement
  • Operations & maintenance provided
  • Remote monitoring
  • Performance guarantee
  • No hassles dealing with direct pay filing

Solar Loan

Solar Power Agreement (SPA)

Designed by nonprofit professionals

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COLLECTIVESUN RESOURCES

Visit our Resources tab at collectivesun.com to learn more about:

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Connect with CollectiveSun

CollectiveSun Statement of Qualifications

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DON’T LET THIS OPPORTUNITY PASS YOU BY

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If you care about climate change and want to do something tangible:

  • Act now
  • Take advantage of the opportunity to save money
  • Be the change you want to see
  • Engage your congregants in going solar too

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Ready to get started? Have more questions?

Contact Lou Stagnitto: 503-997-0970, info@interfaithsolar.org

Contact Rev. Ambrose: 510-369-3541, ambrose@greenthechurch.org

Contact Gregory Stevens: 650-313-3998, gregory@interfaithpower.org

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Learn more:

Interfaith Solar Campaign interfaithsolar.org

Green the Church: greenthechurch.org

California Interfaith Power & Light: interfaithpower.org

NEXT STEPS

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THANK YOU

FOR JOINING US!