Yesterday afternoon, on June 16th, 2025, Mike Crapo, the Chairman of the Finance Committee of the Senate released the Senate’s version of “One, Big, Beautiful Bill” with their Reconciliation Text. The Senate’s version differs markedly from what the House published; it was drafted separately and was not a markup.

This version is not necessarily the final version of the Bill— it will go back to the House, where it has to be approved or amended, as well as worked through a conference committee to reconcile some of the changes, before being sent to the President for signature.

However, in its current form, this is not a good bill for the clean energy industry and could have severe implications for the entire economy in terms of job destruction, energy price increases for households and businesses, and a massive roadblock in the AI race, where cheap and abundant energy, alongside talent and knowledge, is a key resource. Not only are solar and wind the cheapest energy sources, but they are significantly faster to deploy to keep up with new demand stemming from data centers. Moreover, they can be co-located, reducing strain on the grid or the need for often-slow upgrades.

To put the previous point into perspective, a staggering 94% of new capacity in 2024 came from solar, wind or battery storage. Furthermore, 82% of planned grid additions through 2030 come from the same sources of energy, and this pipeline is now at risk.

Jumping to what has been proposed by the Senate: the changes are an improvement versus the last version passed by the House, but they fall short of what is needed and the overall picture is significantly worse than what was expected to be passed by the Senate. While clearly not good news, it is also not as disastrous as the House version.

The key changes, centered around solar, wind and storage, are:

1. There is a phase-down for ITCs and PTCs (48E and 45Y) for wind and solar projects already beginning next year, with timing (very importantly) based on beginning of construction. Credits will be reduced to 60% in 2026, to 20% in 2027, and are fully phased out thereafter. This is 4 years ahead of the IRA’s timeline and clearly bad news, although beginning of construction safe harbors provide clarity for project pipelines and reduce project construction timeline risks and potential financing complications versus PIS-based requirements.
2. Storage, hydropower, geothermal, nuclear and other qualified facilities will not begin a phase out until 2033. This is good news.
3. Transferability is untouched, beyond the implications in the market of the earlier phase out. This is also good news.
4. FEOC (Foreign Entity of Concern) requirements are framed more clearly and with the intention of making them workable. It will be very important to monitor what the final requirements are, because anything close to the House version would be catastrophic for the industry.
5. Residential tax credits (e.g., 25D) are eliminated after 180 days from the passage of the Bill. Moreover, 45Y and 48E are disallowed for leases to residential customers, which is a typical structure in the residential solar industry.

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Additionally, 45X (advanced manufacturing) credits are for the most part untouched  (for example, excluding wind components). 45Z (clean aviation fuel) and 45U (zero-emission nuclear) also emerged largely unscathed. Clean hydrogen credits (45V) are eliminated for any facility beginning construction after the end of 2025. Given the length of the development cycle, this would effectively kill the nascent green hydrogen industry in the US.

While this version can still change, it is unlikely that anything better will come out of a reconciled version with the House, though 13 House Republicans asked the Senate to “undo” some of the changes passed in their version. We still encourage everyone to reach out to their Senators and House Representatives to explain how these proposed regulations impact them.

With that in mind, the best pieces of advice that we can give would be to:

1. Begin construction on projects as soon as possible, and properly document it. We encourage developers to work with their attorneys or CPAs, and we can point people to the right resources if helpful.
2. Monitor FEOC requirements and have a very good understanding as soon as final (or temporary) guidance is released. Recapture is 100% and the timeline is 10 years so it will be important to get it right.

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For more information, please refer to the Bill Text or to the Section by Section Summary, which we have found very helpful to cut to the most important information.

The Concentro team is available for any questions and ready to help; do not hesitate to reach out.

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