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Peter DeFazio

Peter DeFazio is the Managing Director at Greenprint Capital, LLC, based in Solana Beach, California. He has over 18 years of experience in the renewable energy and environmental sectors. At Greenprint Capital, he oversees investments in renewable energy projects, specializing in tax credit acquisitions and sustainable infrastructure financing. Since joining Greenprint in September 2019, DeFazio has been instrumental in facilitating significant tax equity investments to support clean energy initiatives, including large-scale battery energy storage and solar projects.123

Before his current role, DeFazio held several senior positions in the renewable energy industry, including Principal at Symbiont Energy, Senior Vice President at TerraNavigator (now part of Ameresco), and Vice President of M&A and Project Finance at Blue Earth (now BrightMark Energy). He also worked with companies like Clearway Energy Group, Sempra Energy, and San Diego Gas & Electric, focusing on project finance and energy trading.1

DeFazio holds an MBA in Finance from the University of Portland and a Bachelor of Science in Mechanical Engineering from Gonzaga University.1

Highlights

Jul 17 · linkedin

Greenprint Capital has $500MM of tax equity appetite remaining for 2024 that we'd like to deploy. If you have projects that will place in service in 2024, we want to hear from you! We will consider straddle year commitments (2024 and 2025). Send an email to [email protected]. #GreenprintCapital #TaxEquity #RenewableEnergy #Sustainability

Jun 23 · linkedin

Now that IRS guidance on the Inflation Reduction Act (pertaining to tax credit transfers) has been released and we've reviewed a dozen different legal summaries - it’s time for some take aways. I think the IRS did a great job collecting feedback/questions and then addressing issues in a thoughtful manner. However, I think a lot of prayers were left unanswered.

Additionally, there has been some key industry news relating to the Alta wind case, which should be concerning for developers that looking for ITC eligible FMV step-ups in excess of 20-25% on their projects – for those of you not following this… I highly recommend getting up to speed. Check out this article by NRF: https://lnkd.in/gKpdr7Cu

Key guidance take aways - There was a portion of the market hanging on the hope that guidance would allow individuals to participate in the tax credit transfer/purchase market; that hope has been squashed. Our interpretation is that even individuals that are currently active in tax equity using the grouping analysis, can’t buy tax credits on a stand-alone basis unless they have sufficient passive income to use them.

There was also the hope that you could get a step-up on the sale of a tax credit without having to go through an expensive tax equity structure. Guidance didn’t directly address that, but it did open the door for a way to achieve a step-up. Partnerships can now buy/sell credits. This means you could sell a project to the partnership at FMV. That partnership could then transfer the credit. I think this probably will end up being as expensive as tax equity (transaction cost wise) – but does create a way to accomplish FMV goals.

Further, the guidance clarified that a lease-passthrough election (used with inverted lease) was not compatible with a tax credit transfer/sale. We were surprised by this. But in retrospect it makes sense. The inverted lease is way to achieve an ITC based on FMV without having to pay capital gains on the delta between cost and FMV – in effect creating a bit of a tax loophole. We think the structure will still be used by developers, but just not in conjunction with the transferability provisions of the code.

Investment fund managers were hoping that ownership transfer restrictions would be lifted so once a transfer was made to a buyer, the fund could then buy/sell its indirect interests (to other funds or investors) without recourse or penalty. That was also squashed. However, there is a positive outcome for the tax credit buyer here. If a partner in the Seller changes ownership – the tax credit transferee is not subject to recapture. Good news for tax credit buyers.

What's Next?

It’s pretty clear that the new market standard for tax equity moving forward will be to bake in the transferability provision into the partnership flip documents. We’re out of space here but expect more from us later on the topic. We call them T-Flips – short for Transfer-Flips.

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Peter DeFazio
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Location

Solana Beach, California, United States