From IRA to OBBBA: Navigating US Energy Policy with Keith Martin (Norton Rose Fullbright)

Every time the US changes president, the rules around clean energy finance change too. One administration steps on the gas. The next one slams the brakes. Under Biden, the inflation reduction act or IRA turned tax credits into the main engine of the energy transition.

Hundreds of billions of dollars worth of incentives for wind farms, solar parks, energy storage systems, and more. Under Trump, the conversation has flipped With the one big beautiful bill act or OBBBA, the Trump administration is trying to roll back some of the Biden era policies. For the people actually building this stuff, developers, owners, financiers, it's a bit like being halfway through construction on a skyscraper and then being told, actually, you've gotta finish this by next summer or you will lose your permit. That's what the one big beautiful bill act has done for many renewable projects in the US.

It hasn't wiped out the incentives from the Biden era inflation reduction act. What it has actually done is shortening runways and also raising the bar for compliance. And with so much uncertainty, it's harder and harder to build confidence in your business case. And yet, somehow, the deals keep getting done.

And that's partly thanks to people like Keith Martin. Keith runs the US project finance practice of Norton Rose Fulbright, one of the biggest law firms in the world. He has been the steady hand behind hundreds of billions of dollars of projects in renewable energy and energy storage over the last few decades. If you have ever wondered who translate a three hundred page long tax bill into the clause that decides whether solar farm gets built or not, that's people like Keith.

He sits where policy meets money, turning government rules and incentives into language that investors can actually trust. So today on transmission, Keith Martin, the lawyer who has quietly shaped more clean energy projects than almost anyone else in America, helps us unpack how Washington policy has had an impact on real world projects. And before we dive in, a quick plug. The transmission team, including myself, will be at Reuters Energy Life twenty twenty five in Houston this December, recording new episodes and soaking up all of the insights from some of the industry's foremost doers and thinkers.

If you're also attending, drop us a line. Anyway, that's enough of me. Let's hear from Keith Martin.

Keith, thank you so much for joining me today. It's great to have you here.

Thank you for having me, Alex.

And before we dive in, could you please introduce yourself and tell us a bit about Norton Rose Fulbright's work in the energy space?

I'm Keith Martin. I'm in the Washington office of Norton Rose Fulbright. Norton Rose is a old British law firm.

Goes back to seventeen ninety four. It has twelve offices in the US, six in Canada. It's in thirty one countries. I had the project finance group in the United States. I've headed that group for more than twenty five years.

The group came from a New York firm called Chadbourne, Chadbourne Park. We merged with Norton Rose in twenty seventeen. There are a hundred and thirty eight lawyers in the group. We see a lot of the market. Most of what we do in the US is renewables. About eighty five percent of the work of the group the last four years, each of the last four years was renewables, and sixty percent at each of the twelve years before that. We did two hundred eighty eight billion in transactions in the last five years, more than six hundred significant deals.

So you have a lot of coverage and exposure to the renewables and storage space in the US, I can imagine. Yes. You have lived through the transition from the Biden era inflation reduction act to the recently passed one big beautiful act. For people just catching up, with the latest announcements, how would you describe what's really changed under the new bill for wind, solar, and storage products specifically?

Well, two things. Let me start from the law firm perspective. The last two years have been like a treadmill turned up to warp speed. To switch metaphors, the inflation reduction act provided a very strong tailwind for the renewable sector, and lawyers, bankers, everybody working in this sector has been working flat out.

Most of us thought once Trump took office, things would slow down a bit for renewables. In fact, the the pace has doubled.

And instead of a a strong tailwind, there's now almost a hurricane force headwind. As a consequence, people have to work that much harder.

I agree. And this you are seeing keeping for the short term, also midterm, long term. What is the difference?

I think that this will remain a very busy industry.

Most of the large renewable energy developers started construction of pipelines of projects by the end of last year that insulates them from the rollback that occurred in federal tax credits for these projects in the o triple b a, the one big beautiful bill act.

So they're working they're just head down executing business plans. They have a four year pipeline of projects that will take them past the current Trump administration.

The reason I think that even for others who will start to feel the loss of tax credits, that things will remain busy is that we have an electricity shortage in the United States. It's only getting worse.

Electricity prices wholesale prices increased forty one percent in the first seven months of this year in PJM, which is the regional grid that serves the mid Atlantic states all the way out west to Illinois.

Retail electricity prices have been increasing at double the rate of inflation. In locations where there are concentrations of data centers, the electricity prices on average are increasing two hundred and sixty seven percent in the last year.

So this is a sign of increasing shortages of electricity. The government will need every source it can. It'll need storage. It will need wind and solar to try to make up the gap.

What do you think are the main drivers behind these price increases? Are we talking about the lack of future tax credits, the future demand, the current demand? What are the main drivers from your point of view?

Two things. Demand, it's coming from data centers. Data centers right now are about four percent of US demand, but the US government is projecting that by twenty twenty eight will be somewhere between, eight and twelve percent.

And then the second thing is our crowded electricity grid. It's like a congested interstate highway, so it's difficult to get the electricity even if we have it to the places where people need it.

Okay. Yeah. We are seeing the same. But just to give a step back, because we're going very fast in the final results and impacts of of the latest changes in in electricity prices. But what have been the main changes for developers after the OBBA, the One Big Beautiful Bill Act, was passed in terms of timelines in in tax credits as well as start of construction requirements or the recently announced part of of the same announcement foreign entity of concern rules?

Well, the One Big Beautiful Bill Act rolled back or moved in very distant phase out dates for federal tax credits. Federal tax credits pay anywhere from thirty to seventy percent of the cost of renewable energy projects.

They were not expected to start phasing out until sometime in the mid twenty forties according to projections before that bill passed. So now those deadlines are upon us shortly.

And then second, it made it impossible to claim tax credits on projects to start construction this year or in the future that have too much Chinese equipment or rely on Chinese intellectual property rights. The deadlines there are four deadlines that the industry has been racing against. One was to try to start construction by September one. The, treasury department under pressure from president Trump made it tougher for wind and solar projects to be considered under construction to lock in entitlement tax credits. Those rules became tougher for solar and wind, but nobody else starting after September one this year. Second deadline is the end of this year for all projects, not just solar and wind, all renewables, including batteries, to start construction to be exempted from the limits on Chinese equipment under the FIOC rules, FEOC, foreign entity of concern.

The third deadline is July four next year, which is a deadline for solar and wind projects to be under construction to have four years to finish and claim tax credits. If they don't get under construction by July four next year, they must finish by the end of twenty twenty seven.

And then the last deadline is the end of twenty thirty three for everything other than solar and wind to start construction and lock in entitlement to full tax credits.

And we have seen, new guidance coming out of the Department of Treasury talking specifically about the start of construction, new requirements, but we are still waiting for that guidance to come out for the foreign entity of concern rules. Do you have any light on when we can expect those guidance to arrive to to the public and how it will look like at the end?

The FIOQ guidance will take the form of proposed regulations, and those are not expected until the spring next year.

The treasury has suggested it will issue what the lawyers call subregulatory guidance. That is a notice, perhaps a list of frequently asked questions and answers. The treasury had been saying that we'll be out by year end, but the government shutdown could affect the timing of that.

Ken Keyes, the top tax person at the treasury, said yesterday he they are calling back forty five lawyers who are working on guidance and label them essential so that there's no slowdown. However, the government is focused on guidance in the near term that affects individuals like tip taxes on tip income, overtime pay, the Trump I don't know what you call them, Trump accounts where the federal government wants to give one thousand dollars to each newborn baby to invest in an account. They're trying to get guidance out on that first before they turn to things of interest to companies.

Okay. I see. And all of this noise, this uncertainty surrounding developers in the energy space, what does it translate to? What are you seeing about how teams of developers are adapting on the ground because you have been involved in so many projects throughout the last years? What have been the main changes and the real world implications on ground?

Well, it raises questions about what twenty seven and twenty twenty eight will look like the last two years of the Trump term. Yet there is no scenario where gas, natural gas and coal fill in the need for power. First of all, if you order a gas turbine today for a combined cycle plant, you will not get it before two thousand and thirty. That's two years beyond the Trump term.

So the effects we're seeing in the market are increased pace of activity this year.

We are overwhelmed as our other law firms with companies trying to sign contracts with construction contractors and equipment suppliers to start construction of projects.

We are also working on more financing simultaneously than I think we have ever worked on. I've been at this for more than forty years.

I've never seen so many simultaneous deals, and it in the past, people used to send a term sheet and want it back a week from now, now they want it back the same day.

There's a mania about it. We're seeing signs of consolidation.

The smaller developers are having trouble raising the capital they need to hold their positions in line to connect to the grid. They're called interconnection queue positions.

They also face penalties under power contracts if they don't come online on time. So we're seeing consolidation of people without capital.

Our m and a lawyers are busier this year than they have been anytime in the last two years.

We're seeing bankruptcies. There have been three notable bankruptcies in the US renewable sector, Sunnova, Cowen, and Mosaic, all three in June. There are rumors that others are likely to follow this fall. This is again due to constraints on capital.

We are not seeing cost of capital increase. It's been pretty level. Not much changed this year.

So I think those are the main effects.

I see. And it might be a little bit counterintuitive. I would say people would have expected for developers to slow down their development, but we are seeing the opposite, as you mentioned. And you said that you're seeing as many simultaneous deals as you have ever seen in your career. Do these deals focus on specific regions in the US or in specific technologies?

Batteries are they're the I saw some numbers this morning on new capacity additions for batteries. They're astounding.

Most deals we are seeing, though, are solar. Wind has been more challenged just because of the obstacles that the Trump administration is placing in front of wind projects. So there's an awful lot of solar this year.

There there is an awful lot of battery activity. The batteries though face a challenge because they rely on Chinese technology, and so they will run afoul of the FIOC restrictions very quickly. We're going to start to see that happening next year.

On wind, we are seeing a lot of repowerings of existing wind farms where people try to rebuild the projects in order to renew the ten years of tax credits on the electricity output that are offered to wind farms before they go away.

That's where most of the activity is. In terms of regional, there hasn't been much change as far as we can see and where most of it is. Texas is still attracting a lot, mainly because there isn't much regulation down there, not many obstacles to build. Pjm clearly needs electricity.

California, Iowa, you know, the the the normal hotspots remain so.

The fact that you pointed out to battery projects suffering the most from FEOC rules leads to the next question for battery developers, which is how can you ensure that your procure that your supplier complies with the future rules? How can you make sure that you are on the safe side rather than on the gray area when looking at the future guidance that is coming out?

One other thing before I forget on batteries, they're also since so much of the equipment in battery projects is imported, they're also facing these unpredictable tariffs, which are wreaking havoc. How do you protect yourself as a battery developer? Two ways. One is avoid any rights to use of intellectual property in contracts with suppliers.

If you sign or modify such a right on or after July four this year, the contract is automatically considered to give the supplier effective control over your project, you will not be able to claim tax credits.

So that's number one. Number two, in the tariff provisions, you'll have to address tariffs the way the market is doing it, is all known tariffs are included in the equipment price.

Any tariffs that are imposed in the future are usually split in some ratio fifty fifty, twenty eighty, something like that, up to a cap after which the customer can just walk away without having to pay a penalty.

That is very interesting. I also read in some of your latest articles regarding the latest guidance the possibility of some of these rules being retroactive for a short amount of time, maybe the last year when they were drafting them.

What problems does this cause in developers nowadays? What have you been seeing in developers reacting to this potential outlook?

When you say some of these rules being retracted, are you referring to FIOC, tariffs?

Start of construction and Okay.

I don't think the start of construction changes have been a great problem because the treasury managed to find a middle ground.

Trump wanted it to take a tougher position on when wind and solar projects are under construction, but it ended up threading a needle trying to satisfy conservative members of the house who don't want to see any solar or wind projects and more renewables focused senators who were appalled at the suggestions that wind and solar would be canceled.

So they found a middle ground and both sides seemed happy with it, was astounding.

So that was construction start.

On Fioc, the main problem with FIOQ I expect Treasury will find a way to make FIOQ work.

There was a lot of fear among renewables advocates when the FIOC proposals were moving through congress that they were so complicated that they were like a maze out of which no one would emerge alive, and I think the treasury I think the law firms like ours, as we have worked more with the language, are getting more and more comfortable with it, but there are unanswered questions, and I think the treasury will try to make it work, And the evidence of that is the fact that it it found a way to make the construction start revisions work.

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Enjoy the conversation.

Going back to some of the previous topics that we covered, you talked about a lot of deals being closed right now. How are these large deals being structured from a financing point of view? What different types of contract structures are you seeing, and how have they changed in the past decade, especially with the recently passed bill?

Well, there's been a lot of change in the last decade, but let me just start with this year.

Most renewable projects are financed in something called the tax equity market because the government pays so much of the cost through tax credits that the developers cannot use.

So they find a way to barter the tax credits to banks and insurance companies that can use them in exchange for cash.

So that that market is healthy. It has been setting records.

It's about a twenty billion dollars a year market. The Inflation Reduction Act authorized another tool which is called just tax credit sales.

That market has also been healthy, and the tax credits where companies choose to sell them instead of doing complicated tax equity deals are getting generally ninety one, ninety two, up to ninety four, ninety five cents per dollar of tax credit.

And there are lots of transactions. We ourselves have done ten point seven billion in tax credit sales in the last twenty seven months. So that's about a quarter to thirty one percent of the market depending on the year. That new tool, the ability to sell tax credits, has opened up another structure, two other structures. First, the typical tax equity transaction is a partnership, but now these are being structured as hybrid partnerships where a bank or insurance company forms a partnership with the developer. The two of them own the project. The tax benefits are allocated largely to the so called tax equity investor, but now these partnerships are leaving the depreciation with the tax equity investor, but they're selling the tax credits to another company for cash.

That's called a hybrid partnership flip deal. And then there are preferred equity structures which have appeared in the last year or so. There are about a dozen companies offering this where a company plans to sell tax credits, but before doing so, it sells the project into a partnership with a cash investor, and then that partnership sells the tax credits. And the reason this is done is to allow the tax credits to be calculated on the fair market value of the project at the end of construction rather than the bare cost. We're also seeing on the debt side, banks are making bridge loans against future tax credit sale proceeds.

They're both uncovered and covered bridge loans. Covered bridge loans are a loan for ninety five to ninety eight percent of the expected tax credit sale proceeds. In a case where you know who the buyer is, you've already locked that in.

Uncovered are about seventy to seventy five percent of the projected sale proceeds, assuming ninety cents on the dollar, and those are where you don't know yet who will buy.

So that's opened up a new line of business.

We're seeing banks also do construction and development revolvers. They're called borrowing based facilities where they will make a loan to a developer that it can draw down, but it draws down the amount it can draw is a function of how large the value of its assets, its borrowing base.

And then we're seeing pre NTP loans. In the past, the lenders have been unwilling to lend before construction starts. They'll take construction risk but not development risk.

But because of the number of lenders in the market, there are at least eighty competing with each other, they have been taking more risk called they'll take some development risk called pre NTP before notice to proceed with construction.

And then finally, the private equity funds have been lending. They're called private credit lenders. They've been competing with the banks. The banks are complaining that the capital, they need to hold back tier one capital to provide a buffer in case they have bad loans, is holding them back and the the private credit lenders are not constrained by that. They're getting a favorable hearing from the Trump administration which looks like it's about to relax the tier one capital requirements perhaps by about fourteen percent.

All of the different deals and structures are very interesting. And one more point that we have been listening a lot is that everyone loved the simplicity of selling tax credits under the inflation reduction act. But now post OPBA, what's happening in the in the transfer market? Is it still thriving? Is it getting more complicated to do those transfers?

What is your perspective, and what have you been seeing?

It is still thriving. There's been no change in volume.

There were two deadlines we just passed, September fifteen for partnerships to sell tax credits from last year and October fifteenth for corporations to sell from last year, so twenty twenty four credits, and there was a lot of activity ahead of those deadlines.

What we're seeing is that the market will buy any tax credit that has insurance behind it. So there was also the inflation reduction act helped the tax insurance industry. These insurers, there are at least seventeen or eighteen of them who will write insurance on the tax benefits. Lately though, in the last few weeks, we've been hearing from tax insurers that they're having a harder time filling out the excess layers.

When you buy tax insurance, you buy from a primary insurer and then it pulls in others to join along. Those are called the excess layers. For some reason, the break brokers are reporting it's harder to fill out those, and we've been hearing from some developers that they just can't find insurance, but that's a very new development, say, in the last two weeks. People are watching the US claims court for a decision that's expected in November, perhaps December at the latest, in a case called Alta Wind, a l t a, Wind.

That case may have something to say about the amount of the tax credits where tax credits are claimed on the fair market value.

It's called a basis step up from cost. It may have something to say there. The insurers may be pulling back a little bit to wait to hear, to see what the court says.

And you mentioned something, that surprised me, tax credit insurance, companies. What exactly is that? Because I guess that many people in our audience won't know about them yet as well.

What is exactly a tax credit insurance company?

These are insurance companies, that AON, as an example, various Lloyd syndicates. There are at least seventeen of them that that have been running tax insurance for a long time. When I first started, I I started on Capitol Hill in the in the, US Senate as a tax staffer. But when I moved to private law practice, the first thing I did all I did for the first eighteen months was representing Lloyd's syndicates writing insurance on tax benefits.

At that time, it was the airlines who had been given a one year window by Congress to sell tax benefits they could not use on their airline fleets, and so the Lloyd syndicates were writing insurance on those tax benefits to the buyers of them. We've had it a long time. It's picked up in the last five, six, seven years. The brokers have been at all the renewable energy conferences educating the market.

But, in the last year or two since tax credit sales, became possible again, many transactions require tax insurance to close.

Understood. Thank you for explaining the concept of a tax credit insurer.

And then picking up another point that you mentioned before about different states and senators talking about the new act.

I wanted to get your perspective on how those states and regional market operators are have responded to the new federal rules. Are they helping smooth things out, or are are they adding more layers for the pedipers to navigate?

They're not adding more obstacles. They are during the George w Bush administration when the, Republican administration pulled back from renewables, the Democratic led states stepped up and provided incentives at the state level. The most common one were renewable portfolio standards that we have in at least twenty nine states that require utilities to supply a certain percentage of electricity for renewables.

This time, the states have not, as a group, done anything like that, but they certainly are creating obstacles.

What everybody is watching is agency pile on where the interior department, for a start, said that it will not approve any easements, uses of federal land for renewable energy projects, solar or wind, unless the Secretary of the Interior personally approves the yet, and so far he has not been interested in advancing solar and wind.

There are other agencies who have now gotten into the act. The Department of Agriculture has pulled back to incentive programs for solar.

The Department of Transportation is imposing larger setbacks for wind turbines from highways and railroads.

There have been fears that determinations are no hazard by the Federal Aviation Administration, that wind towers need to be erected, no hazard to aviation, commercial aviation, will be harder to get. We have not seen any problems there yet.

The Environmental Protection Agency, the US Army Corps of Engineers, all of them are making it harder for solar and wind to advance. The governor of Nevada sent a letter to the interior secretary. He said the governor is a Republican. He said, I realize the administration wants to promote fossil fuels.

We do not have them in Nevada. What we have are wind and sunlight, and there has to be some way for these projects to get built.

So there there will be more and more friction from Republicans who are worried about rising electricity prices. At some point, lack of electricity will place a brake on economic growth.

I think it was today that I read a new about the governor or senator for Rhode Island also pushing for wind, trying to get some federal support again, or trying to stop the complete fight against wind. What exactly happened? What is your view on that?

His name is Sheldon White house. He is the ranking Democrat on the Environment and Public Works Committee, and the, Congress has been, talking for the last three years, at least probably longer, about permitting reform. There's a there are books out, both about the difference between China and the US and also abundance theory.

Esther Klein, who writes for the New York Times, about how the US is making it too hard for people to build things. And so there's a general sense that we need to do something about permitting, but what White House and his counterpart on the energy committee, Martin Heinrich from New Mexico, have said is they're not interested in permitting reform as long as the administration doesn't follow the law.

White House in particular was complaining about administration's revocation of permits for offshore wind projects, some of which are far under construction.

There is a battle that's interesting to watch right now about the CVOW project, the Central Virginia offshore wind project that Dominion Energy has almost completed. It's over two thousand megawatts.

The governor, Glenn Youngkin, who's a Republican from Virginia, and the local congresswoman have been trying to prevent the interior department from revoking the permit for that project, but there's a lot more noise around it lately that the Republican administration, Trump administration, will pull back that permit. These revocations of permits for empire win, for revolution have felt a little like ransom notes.

The administration wants something in return.

That's they got something in return for Empire off New York to get it going again.

But Doug Bergen, the interior secretary, says they're not looking for any ransom. They just don't like offshore wind, period.

So that that's the battleground. I don't think on permitting reform, there's so much ill will between the Democrats and Republicans in Congress at the moment. There's a general recognition something needs to be done, but there's too much ill will.

It's a little hard to see how it goes forward, although people have not given up.

And then coming back to the overall uncertainty created by the FEOC rules and the start of construction guidelines, We here at Motor Energy focus mostly on on batteries plus solar and then wind as well. And from your perspective, are there any key actionable takeaways or insights that you would give to the developers to confront the finish of of their products for the next three years?

Well, here's my advice. Number one is start construction for tax purposes if you haven't already by the end of this year to avoid part of the Fiat restrictions that limits the amount of Chinese equipment that can be used. You will not escape all of Fiat, but at least you escape that part.

If you can't start by then and your solar or wind start by July four next year so that you have four years to finish.

If you're a battery, you have plenty of time until the end of two thousand and thirty three.

That's part one. Part two, we have been getting lots of requests from manufacturers of batteries and other products, solar panels, cells, so on, to do analyses for them so they can assure their customers they are not foreignities of concern.

That requires looking at their shareholding, their debt, who can appoint their officers and and board members, and we have been working through that with them.

That's where the activity is right now. Construction start ahead of these deadlines and and trying to assess what entities or foreign entities of concern and also scrubbing contracts with Chinese counterparties or counterparties you suspect have are majority Chinese owned, but a lot of people don't have enough visibility, scrubbing them of provisions that give the counterparties effective control over some aspect of your project. If you have such contracts, that will also prevent tax credits from being claimed.

That is very interesting as well. From my general point of view, I would say stepping back from developers, but overall developers, investors, lenders, What do you think are the biggest opportunities and the biggest risks for sponsors and investors trying to navigate all of this in the upcoming years?

Interesting question. I was just thinking this morning about what keeps my group busy.

There are so many opportunities right now. Number one is acquiring assets from developers who don't have the capital. Another is, we're we're extremely busy financing LNG terminals as other countries, shift to gas partly under the pressure of the Trump administration. We are very busy with financings of data centers. We are hearing from lots of real estate developers who want to prepare sites for data centers by by developing their own power supplies. It's so hard for data centers to find electricity at the moment.

Nobody with electricity has trouble finding a buyer for it.

This has been a huge change in most of my career.

I've been working in an industry where people don't want more of the product. They're happy with just the the same amount every year, but all of sudden, we're seeing rapid growth, and that creates opportunities.

We're seeing people start to anticipate a much greater demand for small modular reactors, small nuclear reactors. We've been working with a number of small companies, some developers who are anticipating that they'll switch from solar batteries to this type of asset.

Those, though, aren't really expected to appear in great numbers until sometime between two two thousand and thirty two and two thousand and thirty five. Another thing, fuel cells are are making an end because they can be deployed quickly. They can use natural gas, and therefore they can be a source of electricity.

Another thing, microgrids. The utilities, many of them just don't have the capacity to to provide electricity to new factories or subdivision developments or data centers that want to build in their service territories. There's an opportunity for others to come in and be the the power supply, be the local utility.

And we talked about technologies, about geographies. Have you seen a concentration in opportunities, for example, data centers in PEM or in Texas or for other technologies in other regions where investors or lenders could be very interested in entering?

Well, data centers tend to be concentrated in certain parts of the country. Virginia, for example, Northern Virginia. Richmond is fighting back.

Georgia has a lot of them. California, certainly. We're we're starting to see a turn, though, in that the local committees are fighting back.

I noticed Josh Hawley, who's a Republican senator from Missouri, a conservative, is complaining to Ameren, the big utility that serves Missouri, that the low the local homeowners are are having to pay the cost of new data centers. It's not fair.

And I think you're starting to see pushback, not only electricity hogging all the electricity and pushing up rates for everybody, but also water, which is in scarce supply.

Okay. Thank you. One more question on the personal side. I honestly personally admire you. You have been so many years working in the energy industry. You could be considered a superhero of this energy transition. What keeps you motivated after so many work years working in the in the space?

I like the intellectual challenge.

If this is a good field for anybody who is interested in ideas, there is no shortage of things one could learn about and master. And as soon as you've mastered one, two, three, four, five of them, there are another five that appear. So that that's that's what keeps me going. I also like to write.

So it's it's a challenge to take difficult technical subjects and explain them to a CEO, for example, or a US senator who's not interested in the details but wants the main points.

That's fascinating. On my side as well, it's on the earlier side of my career. But still, I'm very passionate about the energy industry and looking forward to working many more years in this space.

Looks like have quite a few ahead of you.

Yes. Before we wrap up, is there anything you're working on that you would like to plaque or highlight? This is the moment.

We are working on so many things that, I've been you know, I think my group were working seven days a week this this year. It's a pace I think it's hard to keep up. I tell the younger lawyers, you've gotta find a pace like a long distance runner that you can maintain. Don't burn yourself out in a bunch of wind sprints.

And to end, finally, what's a contrarian view you hold about the US energy market right now that most people might disagree with? This is the question that we ask always to all our guests. So open to your perspective.

I think the US went overboard on a hundred percent renewables, just pushing renewables to the exclusion of everything else.

But at the same time, I don't think renewables are are down and out.

If you look at a the latest data, the inner International Energy Agency released, it had shows two trend lines. The trend line from two thousand five through twenty twenty four of new capacity additions for renewables is a steeply rising curve. The trend line for fossil fuels is a slowly falling curve.

This has nothing to do with US incentives, nothing to do with the Trump administration. It's pure economics.

Well, Keith, thank you for so much for sharing such an honest perspective, throughout the whole podcast. It was a pleasure to have you here with us, and I'm sure that our audience will get a lot of insights from the conversation. Thank you again for for joining us.

My pleasure, Alex.