Renewable Energy Memo

May 30, 2011

Taylor English Duma Renewable Energy Blog

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September 8, 2010

IRS Rules That Sale of RECs Triggers Income

Filed under: Uncategorized — Tags: , , , — Jonathan B. Wilson @ 12:34 pm

The IRS, in a recent private letter ruling (PLR 201035003) held that a sale of renewable energy certificates that creates value for the seller is income for tax purposes.

The private letter ruling was requested by a residential owner of renewable energy property that had sold renewable energy certificates to a local utility.  Under the taxpayer’s deal with the utility, the taxpayer was required to sell all of the RECs associated with a new solar PV system to the utility in exchange for payments. 

The IRS distinguished the utility’s payment for the RECs from indirect subsidies which are exempt from taxation under Section 136 of the Code.  Reasoning that the sale of the RECs was like a sale of property, the IRS determined that the gain on the sale would be taxable as income to the taxpayer.

September 4, 2010

Aaron Kowan Speaks on Renewable Energy Tax Credits

Filed under: Energy Blog,Uncategorized — admin @ 12:19 pm

Taylor English Attorney Aaron Kowan, spoke at the Reznick Group’s Real Estate and Renewable Energy Markets Forum at Lowe’s Hotel in Atlanta on August 24th.

Tax credits are a key element in many structured finance transactions involving real estate or renewable energy and Mr. Kowan’s practice focuses on ways to derive cash to fund project development from tax credits.

The Reznick Group is a national accounting firm that has been sponsoring symposiums on tax credit financings for several years. The meetings are generally attended by investors, project developers, bankers, accountants and lawyers looking for ways to structure financings for new projects.

Mr. Kowan is part of the renewable energy finance practice at Taylor English Duma which structures tax credit-driven financings for project developers, sponsors and investors.

March 26, 2010

Colorado Raises its Renewable Portfolio Standard

Filed under: Uncategorized — Tags: , — Jonathan B. Wilson @ 12:54 pm

Colorado Governor Bill Ritter this week signed into law an increase in that state’s renewable portfolio standard (RPS).

Colorado’s HB 10-1001 requires Colorado to produce at least 30% of its electricty from renewable sources by the year 2020.  The state’s goal had previously been 20%, as established in a 2004 law. 

At 30%, Colorado’s RPS is the second most agresssive in the nation, trailing only Maine which seeks to achieve 40% by 2017. 

The bill requires a portion of the RPS to be met through a subset of renewable generation, or “distributed generation” (DG), which does not require additional transmission facilities to connect to the grid. By 2015 and through 2019, 20 percent of retail electricity sales in Colorado must be renewable with DG equaling at least 1¾ percent of retail electricity sales; 30 percent of its retail electricity sales by 2020 and thereafter with DG equaling at least 3 percent of its retail electricity sales. 

The bill will apply to all providers of retail electric service in Colorado, other than municipally owned utilities that serve 40,000 or fewer customers.

The bill’s sponsors say that the measure will create thousands of new jobs as a result of the shift in sources of electrical generation.

December 21, 2009

Renewable Energy Around the Web: December 21, 2009

Our weekly compilation of renewable energy news and information from around the Web. 

Renewable Energy in Scotland

A report from the Scottish National Heritage organization claims that Scotland is on target to exceeds its renewable energy goals and could achieve 300% of its goals by 2020 if pending programs are approved.  The report claims that 2,834 MW of renewable power is operational and another 3,739 MW of power has been approved with another 19,500 MW in the planning stages.  The combined output is more than three times the 8 GW need to meet Scotland’s 2020 target of 50% of electricity from renewables. 

Utilities Building Long Distance Transmission Lines

The California PUC gave its final approval for Southern California Edison to construct the last 173 miles of its 250-mile Tehachapi transmission project in Kern County.  The line is expected to transmit as much as 4,500 megawatts of electricity produced from wind, enough power for nearly 3 million homes.

The capital cost of high-capacity long distance transmission is often seen as a barrier to the development of renewable energy production because the cost can be so high and the time to delivery can take years.

In a related development, LS Power announced that it would build the LaSalle Transmission Project (“LaSalle”), a new 345 kilovolt (kV) transmission project connecting Illinois and Indiana. The project is intended to facilitate renewable energy development within the region.

LaSalle is expected to be an approximately 160-mile transmission line to connect three existing 345-kV substations operated by the PJM Regional Transmission Operator. These three substations are the Pontiac-Midpoint substation near Pontiac, Illinois; the Reynolds substation near Reynolds, Indiana; and the Dumont substation near North Liberty, Indiana. New substations may also be constructed along the transmission line to serve as points where additional wind could interconnect to the transmission system.

“LaSalle will be routed through some of the most promising areas in Illinois and Indiana for wind development – areas that currently have limited access to the high-voltage transmission system,” stated Sharon K. Segner, Director – Project Development with LS Power. “LaSalle will provide both a means for wind generation to connect to the transmission system and an outlet for the wind generation to be delivered to load.”

The project is being developed by Central Transmission, LLC, a new transmission company and member of the LS Power Group. The LS Power Group has active transmission development across the country representing over 1,000 miles of transmission planned to help deliver renewable resources to load. This includes Great Basin Transmission, a new transmission company in Idaho and Nevada developing a “shovel ready” 500+ mile 500-kV transmission line; and Cross Texas Transmission, a new transmission company in Texas developing over 200 miles of double circuit 345 kV as part of the Competitive Renewable Energy Zone Transmission Plan.

Renewable Energy Committee Studies State Incentives

The Renewable Energy Committee of the American Bar Association’s Public Utility Section is conducting a study of state-level incentives for renewable energy.  The Committee’s Fall 2009 Report outlined the key federal incentives and for its Spring 2010 Report the Committee will dig deeper into the incentives available at the state level.  Created by the Public Utility Section in 2009, the Renewable Energy Committee has nearly 100 members and brings together legal practicioners to study developments in the sector.

New Landfill Methane Plant in North Carolina

Methane Power announced the opening of a new landfill gas-to-energy plant in Durham, NC, the state’s fourth largest city.  Electricity generated by the Durham landfill energy plant is being sold to Duke Energy Carolinas under a power purchase agreement.

Methane Power Inc., the project developer, said the energy plant is powered by three of GE’s containerized JGC 320 Jenbacher landfill gas engines. GE’s Jenbacher landfill gas engines are generating 3.17 megawatts of renewable electricity for the regional grid by using the landfill’s methane gas, which is created by the decomposition of municipal solid waste. The facility is generating enough energy to support about 1,800 North Carolina homes.

North Carolina is one of 27 states with a renewable portfolio standard (RPS), which requires utilities to produce a certain percentage of electricity from renewable sources, including biogas. North Carolina’s RPS requires that by 2021, utilities must meet 12.5 percent of customers’ energy needs through energy efficiency savings or renewable energy production.

Copenhagen’s Effect on Renewable Energy

Will the recently-announced climate change deal at Copenhagen have an effect on the market for renewable power?  The popular investing blog, SeekingAlpha, things so.  SeekingAlpha writes:

“The result from Copenhagen boosted the renewable energy outlook; India’s Suzlon sees wind turbines shortfall in 2010 and in the coming years. The $53B wind turbine market means the current global capacity cannot meet the demand.”

“The wind energy market is heating up in China as well. Ealier this year General Electric set a joint venture with A-Power Energy Generation with an annual 2GW capacity in 2010. According to the CEO, GE sees China as leading the green energy trend already, and this will continue if the U.S. does not come up with a green energy policy. A-Power Energy Generation announced Wednesday that the company has signed a definitive agreement with US-REG and Cielo wind for a Texas 600MW wind farm project. ”

“Before this announcement, some investors were still skeptical. What makes this project golden is that A-Power has agreed to deliver wind turbines beginning in March 2010. In other words, revenue on wind turbines will starts to flow in Q1 of 2010. Of course, the company has already realized revenue from Chinese wind farms in Q4 2009, however this marks the first revenue in-flow from a Mega wind farm project that A-Power has signed. The company has many huge alternative energy projects from various countries and is ramping up its turbine projects quickly through a Joint venture with General Electric.”

On the other hand, most environmental activists have viewed Copenhagen as a bust, so any boost for renewables is likely less than would have been the result if world leaders had adopted a wider-reaching or more robust agreement. 

In that same vein, on the first tradng day after the Copenhagen announcement, the price of carbon trading permits in Europe fell, reflecting the decreased likelihood of restrictions on carbon emissions.  Bloomberg reported that the “nations attending the two-week Copenhagen summit that ended at the weekend agreed to voluntary, rather than binding, targets to reduce emissions. The accord isn’t enough to boost demand for permits, said Trevor Sikorski, an emissions analyst at Barclays Capital in London.”

November 23, 2009

Renewable Energy Around the Web: November 23, 2009

Our weekly compendium of renewable energy news and information from around the Web.

Trony Solar IPO

Chinese PV manufacturer Trony Solar is looking to raise $241 million in its planned initial public offering.  J.P. Morgan and Credit Suisse are said to be the lead underwriters in the offering. 

Atlanta Foodservice Runs on Biodiesel

The Atlanta division of U.S. Foodservice is now running on biodiesel.   The Atlanta division’s 185 tractors began using biodiesel fuel early in November following the first 7,500-gallon delivery of B5. In addition to using biodiesel blends in the tractors, the fuel will power the four-cylinder, Thermo King Engines in its 210 refrigerated trailers.

Atlanta joins the U.S. Foodservice division in Plymouth, Minn., which uses B5, and the Streator, Ill., division which uses B11 in all but the winter months. The Minnesota facility has used biodiesel blends for years, the company stated, starting with B3 and switching to the state-mandated B5. “The division has had no performance or engine longevity issues,” a company spokesman said. U.S. Foodservice Minnesota is exploring a switch to B10 ahead of a state-mandate increase that takes effect in 2012.

U.S. Foodservice-Atlanta is active with and has a leadership role in several local, regional and state efforts to promote and protect the environment including the Georgia DNR Project, Partnership for a Sustainable Georgia and the Atlanta Zero Waste Zone.

Danish Ethanol

Inbicon unveiled a 1.4 MGY cellulosic ethanol demonstration plant in Denmark, using wheatstraw as its initial feedstock.  Inbicon has been working in partnership with Danish governmental energy authorities and the unveiling was timed to coincide with the climate change conference in Copenhagen

Portable Solar

The BBC ran a lengthy article on applications for portable solar power.  Portable solar can be an efficient solution for devices that would ordinarily run on batteries or that would require new powers lines to connect to the grid, including street lights and signs. 

Push for Extension of Biofuel Tax Credit

The National Biodiesel Board voiced its support for two bills pending in Congress that would extend the biofuel tax credit program that expires at the end of 2009.  (H.R. 4070 and S.B. 1589).  During visits with lawmakers, biodiesel industry leaders expressed strong support for S. 1589, the Biodiesel Tax Incentive Reform and Extension of Act, introduced by Senators Maria Cantwell (D-WA) and Charles Grassley (R-IA), and H.R. 4070, companion legislation introduced yesterday by Representatives Earl Pomeroy (D-ND) and John Shimkus (R-IL). This legislation would reform the biodiesel tax incentive by changing the current blenders excise tax credit to a production excise tax credit. This will improve administration of the incentive, eliminate potential abuses and improve tax compliance. The proposals would also extend the biodiesel tax incentive for five years, providing the certainty entrepreneurs need to create jobs and expand the use of biodiesel.

Comings Events in Renewable Energy

The Renewable Fuels Association is hosting its 15th Annual  Ethanol Conference in Orland, Fla. on  February 15-17, 2010.  Panels will cover the indirect land use charges debate and the path forward for commercialization of biofuels.  Registration before January 22 will get members a discounted entrace for $550 ($750 for non-members).

Registration is still open for the Canadian Biofuels Summit to be held in Vancouver, BC November 30 to December 2, 2009.

50 Hottest Companies in Bioenergy

Ballots are due today for the Biofuels Digest “50 Hottest Companies” competition. 

Write to Us!

We’d love to hear from if you have an idea for a story or would simply like your renewable energy company covered.  Write to us at “editor at renewableenergymemo dot com”.

November 11, 2009

Health Care Bill Cuts Biofuel Tax Credits

A provision in the health care bill passed by the House of Representatives over the past weekend (H.R. 3962) would cut the tax credits currently benefitting cellulosic ethanol and other biofuel tax producers.

Section 555 of the bill excludes from the cellulosic biofuel producer credit (under Section 40(b)(6) of the Internal Revenue Code) any fuel that (a) consists of more than 4% water and sediment or (b) consists of more than 1% ash. 

In an attempt to generate revenues to pay for the costs of expanded health care, the House bill eliminated tax credit provisions that are expected to return $24 billion to the U.S. Treasury over the next 10 years.  Members of the House from Midwestern and other farm states who voted in favor of the bill have already staked out positions in favor of eliminating the tax credit cut in the final version of the health care bill.

November 9, 2009

Renewable Energy Around the Web: November 9, 2009

Our weekly compilation of renewable energy news and information from around the Web.

Xcel Biomass Project Moves Forward

An Excel Energy biomass project in Wisconsin has been given a greenlight by the Wisconsin Public Service Commission.  After three years of project planning and evaluation, Xcel Energy will be permitted to convert a former coal-fired power plant into the largest 100 percent woody biomass-fired power plant in the Midwest.

The Public Service Commission of Wisconsin granted project approval beginning in November, roughly eight months after Xcel submitted its application. The power utility will now convert the last of the three boilers at its Bay Front Power Plant in Ashton, Wis., to utilize a biomass gasification technology. The remaining two boilers have combusted woody biomass for the past 30 years.

In its entirety, Xcel Energy expects the project to cost $58.1 million, which includes additional biomass receiving and handling facilities at Bay Front, an external gasifier, modifications to the boiler and an enhanced air quality control system.  The primary fuel source at the 60-megawatt (MW) plant will be forest waste from surrounding areas. Once fully operational, the entire plant will require 400,000 to 450,000 tons of woody biomass per year.

Conference Recommends Coal Retrofits

Speakers at the Great Plains Institute recommended converting coal-fired plants more than 25 years old to synfuel / biomass co-firing as the best method to reduce GHG from this aging plants. 

Robert Williams, senior research scientist at the Princeton Environmental Institute argued that the best way to reduce greenhouse gas (GHG) emissions from coal-fired power plants in the U.S. is to replace plants that are more than 25 years old with facilities that coproduce electricity and synthetic fuels from coal and biomass while employing carbon capture and storage systems.

Williams made these statements at the GPI conference in Faro, N.D. before a crowd of about 115 people.  The conference, titled “The Future of Coal and Biomass in a Carbon-Constrained World: Technology and Policy Opportunities for the Midwest,” featured several topics and speakers from as far away as China. Tackling both coal power and transportation emissions simultaneously is the best option for meeting that 80 percent goal, Williams said. “That’s a very daunting task,” he said. “We need to make radical change and we need to get underway soon.”

Retrofitting existing coal power plants with carbon capture and storage systems is one option, but Williams said it’s extremely expensive and energy- and water-intensive. Completely replacing the systems not only leads to decarbonized energy, he said, but also enables coal to play a major role in the realization of zero GHG emissions in the production of synthetic transportation fuels. The replacement would mean a switch from combustion to gasification, which allows a relatively simple carbon dioxide removal, Williams said.  A coproduction system with carbon capture and storage producing two-thirds synthetic fuels and one-third electricity, fired by 11 percent biomass, reduces system-wide GHG emissions by 50 percent, whereas a system with 38 percent biomass reduces emissions by 90 percent, he cited.

In Other News . . .

Jim Lane, the editor of Biofuels Digest, has an e-book out called Citizen Cane: Essays for New Days in Bioenergy.  The work explores current topics in biofuels and bioenergy.

KLM Airlines is going to begin running test flights, with passengers, on its jets flying on biofuels.  Flights will begin on November 23. 

A Swiss investment firm has bought the 5 Mgy biodiesel plant of Tri-City Energy in Keokuk, Iowa.  The plant had been slated for auction in December.

TAC Energy has bought Fuel Managers, Inc., in a deal that combines two large fuel distributors.  The combined entity will have more than 2 billion gallons of capacity with sales in all 50 states.

Second generation ethanol producers are asking for improved federal subsidies and supports.  In testimony before Congress in late October the CEOs of several ethanol producers said that current loan guaranty and tax credit programs are proving to be insufficient to generate the capital needed to break ground on new projects. 

Write to Us

We want to hear from you!  If you have an idea for a story or would like to get your company mentioned please write to us at “editor at renewableenergymemo dot com”.

October 19, 2009

IRS Memo Provides Guidance on Black Liquor Tax Credits / Producers May Continue to Obtain Credits through 2012

 A recently-published memorandum from the Office of the Chief Counsel of the IRS may provide additional guidance to biofuels producers on their ability to obtain tax credits. (IRS Chief Counsel Advice 200941011).

The memorandum, penned in June but publicly-released in October, 2009, concludes that (1) ‘black liquor’ generated in a kraft mill in the paper manufacturing process may qualify as “liquid fuel derived from biomass” under IRC Section 6426(d)(2)(G), (2) the combination of black liquor with at least 0.1%diesel creates an “alternative fuel mixture” for purposes of determining the alternative fuel mixture credit under Section 6426(e) and (3) black liquor may also qualify for the cellulosic biofuel producer credit under IRC Section 40(b)(6) but a producer may not utilize both the mixture tax credit (under 6426(e)) and the producer tax credit (under 40(b)(6).

The analysis is important because the mixture credit amounts to only $0.50 per gallon (and requires the addition of diesel or another taxable fuel) while the cellulosic biofuel credit amounts to $1.01 per gallon and does not require any fuel mixing.

Even more importantly, the mixture credit program expires at the end of 2009, while the cellulosic biofuel credit continues until the end of 2012, so producers who are contemplating a sunset of their mixture credits at the end of the year could have three more years of credit under the cellulosic biofuel program.

Most pulp and paper producers are currently receiving the 50 cent alternative fuel mixture credit. In order to receive the $1.01 cellulosic biofuel credit, producers will have to take the additional step of registering under the EPA Renewable Fuel Standard Program.

September 28, 2009

Renewable Energy Around the Web: September 28, 2009

Our weekly compilation of renewable energy news and information from around the Web.

The Saudi Arabia of Biomass

Is North Dakota the Saudi Arabia of Biomass?  It was Shane Goettle, commissioner of the North Dakota Department of Commerce who used this colorful term to describe the state at a the Norther Plains Bioeconomy Conference on September 22 in Fargo, N.D.  Goettle said the state leads the nation in biomass production capacity and is the top producer of 16 different commodities. 

Goettle said that the state has several energy assets, including the largest deposit of lignite coal in the world, the fifth largest oil production state in the nation, and the leader in the nation of wind energy potential. “You would be heavy pressed to find a state that is more readily poised to engage in the country’s energy future,” he said. “The fact that we have such tremendous biomass potential is getting the attention of significant investors, companies and players in the world.”

The North Dakota legislature has created EmPower ND, a statewide energy policy commission to build on a comprehensive energy policy for North Dakota.

The goal of of EmPower ND is to grow all energy industries in the state—renewable and traditional. Goettle said the program is unique in nature. “We’ve got all of the energy industry leaders together to hammer out a policy they we can initially agree on, and go to the legislature and our government leaders to move all of North Dakota’s energy interests forward. It’s not easy work, but I’m very proud of this 14-member commission.”

So far, during 2009 the North Dakota legislature has passed nine pieces of energy legislation supported by EmPower, including tax breaks for renewable energy devices, income tax credits for soybean and canola crushing costs, a combined renewable energy and biomass incentive programs with $3 million in funding, and a biofuels blender pump incentive program with up to $2 million in funding.

Political Favors?

The Wall Street Journal reported last week that Fisker Automotive Inc., a start-up company based in California, will receive a $529 million government loan to build an $89,000 hybrid vehicle in Finland.  The announcement  follows a $465 million government loan to Tesla Motors Inc., which is hoping to manufacture a $109,000 British-built electric Roadster. Tesla is a California startup focusing on all-electric vehicles, with a number of celebrity endorsements that is backed by investors that have contributed to Democratic campaigns.  Fisker is reportedly backed by Al Gore.

The awards to Fisker and Tesla have prompted concern from companies that have had their bids for loans rejected, and criticism from groups that question why vehicles aimed at the wealthiest customers are getting loans subsidized by taxpayers.

“This is not for average Americans,” said Leslie Paige, a spokeswoman for Citizens Against Government Waste, an anti-tax group in Washington. “This is for people to put something in their driveway that is a conversation piece. It’s status symbol thing.”

DOE officials spent months working with Fisker on its application, touring its Irvine, Calif., and Pontiac, Mich., facilities and test-driving prototypes.  Matt Rogers, who oversees the department’s loan programs as a senior adviser to Energy Secretary Steven Chu, said Fisker was awarded the loan after a “detailed technical review” that concluded the company could eventually deliver a highly fuel-efficient hybrid car to a mass audience. Fisker said most of its DOE loan will be used to finance U.S. production of a $40,000 family sedan that has yet to be designed.

Subsidies for Non-Renewable Fuels?

Biodiesel Magazine is reporting that a recent study by the Environmental Law Institute concluded that existing subsidies for fossil fuels provide twice the value in governmental incentives to fossile fuels than to renewable fuels.  The study claims that fossil fuels benefited from approximately $72 billion over the seven-year study period, while subsidies for renewable fuels totaled only $29 billion. More than half the subsidies for renewables—$16.8 billion—were attributable to corn-based ethanol. Of the fossil fuel subsidies, $70.2 billion went to traditional sources—such as coal and oil—and $2.3 billion went to carbon capture and storage, which is designed to reduce greenhouse gas emissions from coal-fired power plants. The focus of the study was that these energy subsidies  favored energy sources that emit higher levels of greenhouse gases over sources that emit fewer greenhouse gases.

Cash is King

Popular investing website, Seeking Alpha, carried a lengthy report on the economics of renewable energy investing.  Among its findings:

  • It is a “buyer’s market” for those developing large wind, solar, bioenergy, biofuel, and other renewable energy projects. In 2009, land is less expensive, equipment cost less, deliveries are faster, and warranties longer. It is a buyer’s market if you have cash, yet it continues to be a difficult time to secure debt financing.
  • Demand for renewable energy is at a record high as U.S. utilities in about 30 states struggle to meet renewable portfolio standards (“RPS”).
  • Utilities in RPS states are looking to sign long term PPAs (“power purchase agreements’) for 5 to 20 years.
  • Renewable energy has been an “historic opportunity” for developers who would take projects through 3 to five years of analysis, regulatory approvals, securing equity and debt financing, buying equipment, program management, and operating the plant. Now, few investors and lenders have the appetite for risk, as projects such as ethanol plants have gone bankrupt.
  • Credit worthiness of developers, utilities and end users are scrutinized. For example, major public real estate owners of buildings, hotels, and shopping centers that want MW of solar cannot get the RE because their corporation or REIT has a sub-prime debt rating.
  • Risk is intensified as redundant regulation and NIMBY (not in my backyard) opposition can delay installation of high-voltage lines for 7 to 10 years from wind or solar farm to major cities that need more electricity. Even billionaire Boone Pickens was unwilling to tie-up money for that period of time.
  • Although large-scale RE development in 2009 is beyond the financing capabilities of most entrepreneurs, it is an opportunity for major public companies with investment-grade bond ratings such as FPL Energy (FPL), GE Energy (GE), Iberdrola Renovables (IBR.MC), and EDF Energy Nouvelles (EEN.PA). Wall Street analysts are forecasting record 2009 and 2010 earnings for Iberdrola and EDF.
  • Smaller wind and solar developers find that new developments are possible, though more difficult. Utilities are standardizing RFPs and making conditions more reasonable. Private equity money is available if investors can be convinced of high returns and low risk. David Perlman, Managing Director with investment banker Fieldstone Private Capital Group, reports that, “Liquidity is returning, but with fewer banks than before economic crisis, smaller lending commitments, shorter maturities, and club deals rather than syndications. Bankers might offer construction terms and an operating loan of no more than five years for developments that show little risk.
  • The ARRA (American Recovery and Reinvestment Act) has helped and hurt. More federal bureaucracy and slower release of money is reported. New wind and solar deals are more likely to use ITC than PTC. The cash flow for an ITC is sooner and more predictable. For many projects, the new Treasury Department Grant is even more favorable than ITC. Tax-exempt bonds are another avenue for financing RE projects reported John M. May, Managing Director of investment banker Stern Brothers. He identifies bioenergy and biofuel from solid waste are good targets for tax-exempt bonds.
  • The demand is growing for renewable energy and fuels. The rewards are significant for the patient investor who can moderate risk with a portfolio of RE projects at various stages of approval. In 2009, the year of the Great Recession, cash is king.
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