Infratil Newsletter - Impacts of the One Big Beautiful Bill

Infratil Limited 5 Market Lane, PO Box 320, Wellington, New Zealand Tel +64-4-473 3663 www.infratil.com
9 July 2025


Infratil Newsletter – Impacts from the One Big Beautiful Bill Act

The One Big Beautiful Bill Act was passed by the United States Congress and signed into law by
President Donald Trump on 4 July 2025. The legislation outlines key elements of the
administration’s second-term fiscal agenda, including changes to tax policy, federal spending
priorities, including changes to tax incentives for renewable energy projects used by Infratil
portfolio company Longroad Energy.
While the legislation scales back incentives introduced under the Inflation Reduction Act of 2022,
the changes were materially better for Longroad than expected at the time of our annual results
in May (which were based on the original House version). A table comparing the changes is
outlined below:
Provision Original House Version Final Version
Tax Credit Eligibility
(ITC / PTC)
Projects must have started
construction within 60 days of
enactment and be placed-in-
service (“PIS”) by 31 December
2028.
Projects that have started
construction within 12 months of
enactment maintain full eligibility
to tax credits and have four
years to be PIS.
Projects starting after the 12
months must be PIS by 31
December 2027.
Transferability of Tax
Credits
Eliminated for projects not PIS
by 31 December 2028.
Transferability preserved for
most credits.
Foreign Entity of
Concern (“FEOC”)
Rules
FEOC restrictions begin 1
January 2026. Projects using
components from FEOCs (e.g.,
China, Russia, North Korea,
and Iran) are ineligible to claim
tax credits.
Applies to projects that have
started construction after 31
December 2025. Eligibility is
subject to defined material
assistance thresholds (starting
at 40% for solar and 55% for
BESS and increasing from 2026
onwards).
Wind / Solar Excise
Tax
Senate Version: Up to 50%
excise tax for wind and up to
30% for solar for violating FEOC
/ material assistance rules.
No excise tax.

In summary, projects now have longer to safe harbour (12 months vs. 60 days) and longer to build
(4 - 5 years vs. ~2.5 years), tax credit transferability remains intact, and FEOC requirements are
more navigable with the ability to safe harbour to provide more time to transition alongside local
efforts to increase U.S. manufacturing capacity.
However, further clarity on implementation is now expected following an executive order signed
by President Trump on 7 July 2025. The order directs the U.S. Treasury to issue updated
guidance within 45 days to ensure construction-start rules are not circumvented through “artificial

2
acceleration or manipulation.” This could result in a narrower interpretation of safe harbour
provisions - particularly around the physical work test - though any changes are expected to be
prospective in line with past practice. The executive order also reaffirms the Treasury’s mandate
to implement FEOC restrictions, which apply only to projects that begin construction after 31
December 2025. Importantly, the Bill codifies the existing construction-start rules into tax law for
the purpose of FEOC determinations, providing greater legal certainty in the near term.
Under the Bill, technologies such as nuclear, geothermal, and hydrogen retain their original
timelines, with credit phase-downs beginning from 2033. Positively, so have battery storage
projects, with phase-downs not starting until 2034, however the FEOC rules will need to be
navigated carefully for battery storage projects given reliance on Chinese imports (for projects
that have not already started construction by the end of 2025). Longroad’s strong relationship
with First Solar and its American-made solar technology will allow it to more-easily navigate FEOC
rules for solar projects.
Longroad is well positioned to navigate these changes, viewing the legislation not as a setback
but as a strategic opportunity. With over 30GW of utility-scale wind, solar, and storage projects in
its development pipeline, Longroad is focused on leveraging the Bill’s safe harbour provisions by
meeting key construction and in-service deadlines. This strategy helps preserve eligibility for
federal tax incentives across a significant portion of its portfolio, supporting ongoing development.
The company currently has ~2.6GW of projects already safe harboured (up from 1.8GW at the
time of our annual results), targeting additional safe harbouring by the end of the year to enable
it to meet its target of 1.5 GW on average per year of new project starts (FNTP) across 2025 -
2027. There is also the potential that the safe harbor mechanism will be available to qualify a
further 1.5GW per year until the 2029/2030.
The Bill coupled with the executive order, reinforces Longroad’s disciplined approach to
execution. Its experience across interconnection, permitting, and supply chain management
position it well to meet safe harbour requirements across a substantial share of its pipeline. While
tax credits have been highly beneficial for Longroad, the final legislation provides more time than
expected for the industry to transition, alongside continued strong demand for power, which
supports attractive development returns for scaled developers.
This combination of execution strength and enduring demand from long-term offtake partners
gives Longroad a strong platform to deliver on its growth ambitions. Its long-standing relationships
with high-quality counterparties continue to underpin robust demand across its development
pipeline, with many seeking reliable, long-term access to clean energy. This commercial demand,
combined with expected growth in U.S. electricity consumption driven by electrification, data
centre expansion, and domestic manufacturing, provides a strong foundation for Longroad’s long-
term aspirations. These tailwinds further support the business’s confidence in delivering on its
2028 targets and continuing to generate sustained value for Infratil shareholders.
We look forward to hearing more from the Longroad team at our annual Infratil Investor Day in
September, where they will provide a direct update on their progress and outlook.

Enquiries should be directed to:

Mark Flesher
Investor Relations
Email: mark.flesher@infratil.com
Authorised for release by:

Andrew Carroll
Infratil Chief Financial Officer