Podcast: The Impact of the Inflation Reduction Act on the Loan Programs Office

Taite McDonald: Hello and thank you for joining us today. I'm really excited to be here on another Holland & Knight podcast. This is Taite McDonald, as many of you know, I'm a partner here at Holland & Knight and have been a partner at Holland & Knight for about eight years now, but have been in this space for a very, very long time talking about the DOE loan programs office for a very long time. So I just could not be more thrilled today to have Jigar Shah here with us, the executive director of the DOE Loan Programs Office, again, to talk about very new content, the Inflation Reduction Act. And then also my partner, Justin Boose, who has been principal project counsel to Generate since they were founded in 2014. So we're really excited for a productive dialogue.

The Breakdown: What's in the Inflation Reduction Act for LPO?

Taite McDonald: A little bit of a celebration today about the DOE loan programs office, but also to just preview all the work there is to come and all the opportunity there is to come, but also the challenges and obstacles that will still remain ahead of us. So before I turn it over to Jigar to talk about the provisions, I'm going to highlight what's in the Inflation Reduction Act for the DOE loan program. So number one, first and foremost, $40 billion of authority for Title 17, which includes the renewable energy, fossil energy, nuclear programs. We'll talk a little bit more about how that's going to shape up and how that's changing. But overall, $40 billion of authority is a big deal. Plus, for the first time since 2009, we have a substantial amount of credit subsidy cost, which essentially means to folks just starting to learn about the program, it means lower interest rates to you. So $3.6 billion of credit subsidy cost in Title 17 and then in the Advanced Vehicles Program, $3 billion of new authority, which will essentially equal, could equal up to $10 billion of transactions plus expansion to aviation, marine as well as heavy duty transportation. And then really, a lot of people, especially those who have been following these programs, know a lot about Title 17 and ATVM, but now, in addition to additional capacity in those two programs, the Inflation Reduction Act is going to provide us $250 billion of authority under a new energy infrastructure reinvestment financing program, which we'll talk about today as well. So that's something that really hasn't been discussed yet, hasn't been previewed a lot, but really exciting opportunity for utilities and a lot of other infrastructure players in this space that are looking to move to net zero. And then of course, last but not least, the other significant expansion is the tribal energy program going from $2 billion to $20 billion of authority. So with that, Jigar, why don't we talk a little bit about implementation and what's to come?

Jigar Shah: Can't we just celebrate the passing of the Inflation Reduction Act a little longer?

Taite McDonald: No, no. People have been waiting Jigar, people have been waiting. It's time to do the work!

Jigar Shah: Well, it's great to be here and thank you for having me on. I think there's definitely a lot of details to talk through.

Taite McDonald: So where should we start? Do you want to start with Title 17 and what, that's going to be the easiest to implement?

Jigar Shah: Yeah, let's do it.

Taite McDonald: So let's start right there and then we can go through each program.

Title 17 Innovative Clean Energy and Tribal Energy Loan Guarantee Programs

Jigar Shah: Well, what I would say is that I think that the money that goes into the existing programs, whether it's Title 17, the $40 billion of additional loan authority, or whether it's the additional credit subsidy for ATVM, which I think our math is, is that the $3 billion should add an additional $40 billion of loan authority.

Taite McDonald: I was being very conservative.

Jigar Shah: And then the tribal energy loan guarantee program, which is $20 that's roughly $100 billion of loan authority, which should be relatively immediately available. Right, because the programs are already in place. They're already, you know, like the rules are already in place, the solicitations are out there. And so we don't expect any delays in those programs having access. For Title 17, for sure there's really no delays there. I think the only thing that we're probably going to have to work through is implementing the access to critical minerals in Title 17 that was given to us in the bipartisan infrastructure law. So we'll have to figure out exactly how to do that while still maintaining sort of the innovation in greenhouse gas emission provisions that are in there. So there's some conflict there that we'll have to work through.

I think the only thing that we're probably going to have to work through is implementing the access to critical minerals in Title 17 that was given to us in the bipartisan infrastructure law. So we'll have to figure out exactly how to do that while still maintaining sort of the innovation in greenhouse gas emission provisions that are in there.

Advanced Technology Vehicles Manufacturing (ATVM) Loan Program Expansion

Taite McDonald: Perfect. And especially with regard to the expansion on ATVM, because that's something that, as we both know, industry has been eyeing and waiting for. How long do we expect that to take and what's your current plan for the companies moving into that?

Jigar Shah: Yeah, look, I think that, you know, we're already accepting applications for the additional build categories, right? Whether it's clean aviation or locomotives or, you know, maritime or I mean, I think even the Hyperloop is in there. But you can imagine getting final determinations from general counsel will probably take four or five months. And so we're going through that process now. But I think that timing is well aligned with the timing of the application process anyway. So I don't know that we're holding anybody back, but I do think, you know, on the Title 17 side, we have an RFI that we put out the request for information which closed August 1st. We got thousands of pages of comments. We'll start another notice of proposed rulemaking probably in October, and hopefully we'll get that done later this year and then, you know, published next year. And so that'll take care of all the Title 17 stuff. My sense is that timeline is similar to when we can really get people the nitty gritty details around where the edges are for each of the expanded authorities under advanced technology vehicle manufacturing program.

My sense is that timeline is similar to when we can really get people the nitty gritty details around where the edges are for each of the expanded authorities under advanced technology vehicle manufacturing program.

Taite McDonald: Yeah, I really agree with this because, and I think this is important to reiterate a little bit on the timelines because, especially companies and we'll talk about this a little bit Justin will talk about this a little bit later in the dialogue, but overall, it takes companies a significant amount of time, no matter how prepared your project is, no matter how ready to market you are to go. I can't tell you how many times we have companies come to us and say, "We're ready to go tomorrow." And then we go back and we say, we need these 17 documents then and we can start to actually move that into an application. And folks say, "Oh, it'll take me four weeks to get you documents one through five, but I have six through ten or something." So I think it's really important for companies to start now, even if you do not think you are ready, because no matter how much I've been doing this for 15 years since the first iteration of the program, no matter how ready you think you are, there are going to be multiple things that you have not thought about yet that are really necessary to get into the process. So I think it's really worth reiterating this point that it's good to start preparing, even though we are going to have rule makings for some of these. And there may be some gray or there always is these days with the government and implementation, it's across all of the executive branch agencies. It's not just DOE. It's really important to start, because of the time that not only will it take for you guys and implementation, but also for the companies to put together the package. I just think we can't stress that enough.

I think it's really worth reiterating this point that it's good to start preparing, even though we are going to have rule makings for some of these. And there may be some gray or there always is these days with the government and implementation, it's across all of the executive branch agencies. It's not just DOE. It's really important to start, because of the time that not only will it take for you guys and implementation, but also for the companies to put together the package.

Jigar Shah: Oh, I totally agree. I mean, since I've been in office, I'd say that, you know, I don't think we've ever been the long pole in the tent. I think it's always the company. The company makes representations and promises to us that then ends up taking them three months longer to meet.

Energy Infrastructure Reinvestment Financing Loan Guarantee Program

Taite McDonald: Exactly. And working together is the only way it works. So, yeah, before we go on and on about that, why don't we talk real quickly about the utility program expansion, technically, the energy infrastructure reinvestment financing, because that's the one that is brand new folks don't know about and I think has a tremendous amount of value that organizations of all types should start looking at right away.

Jigar Shah: Yeah. So I mean, our initial read of that program is that it, it was really modeled after the 1702 authority. So as a result, we think we can start taking applications for 1706 immediately. And so people I think are preparing applications into our office immediately. We do need to still flush out all the rules and things under the rulemaking, and so that will be completed sometime in January or February. And so that timing I think lines up, but we don't think we have to wait for implementation to get 1706 applications flowing into the office because they really use the 1702 template to create this new authority.

So I mean, our initial read of that program is that it, it was really modeled after the 1702 authority. So as a result, we think we can start taking applications for 1706 immediately.

Taite McDonald: Completely agree and if you're not going to change it. Why wait, right? If it's just going to be implemented the same way as 1702 and it can be from a legal perspective, there's no need to wait, especially when we have the application instruction across the other programs.

Jigar Shah: That's exactly right.

Taite McDonald: But before we leave that too, let's talk a little bit about the types of projects that we think can go under that, because what's really exciting to me is a conversation we had the other day about net zero applications for hospitals for universities. There really is a lot of flexibility in that program.

Jigar Shah: Yeah, I mean, I think that the nexus of the program is really a definition of energy infrastructure. Right. And so I think what's obvious is coal plants, natural gas plants, old pipelines we're already getting lots of calls from people who have pipelines that just don't have they're like superfluous. And there's a new natural gas pipeline that's better than the old one. And so they want to repurpose the current one. Refineries, there's a bunch that have been announced to be shut down in the next two years. And so a lot of them have contacted us to see if they could repurpose their refinery. But even like nuclear plants like Palisades and others. Right, because it doesn't say fossil energy infrastructure, it says energy infrastructure. So taking the Palisades nuclear plant and turning it back on should probably qualify under this statute. And then the parts that I think are a little less clear, but ones that we're pretty confident will be included are things like converting all sorts of backup diesel generators at everyone sites to, you know, battery storage, let's say, or taking abandoned mine lands and converting that to new, more useful purposes. You know, that is an extension of energy infrastructure. And so we think that this gets very broad very quickly. And it's certainly our intention to get as many comments as we can from stakeholders and to see how broad stakeholders want us to make it. But we, we think that this can actually be quite expansive.

We think that this gets very broad very quickly. And it's certainly our intention to get as many comments as we can from stakeholders and to see how broad stakeholders want us to make it. But we, we think that this can actually be quite expansive.

Taite McDonald: Yeah. And just to just to put a finer point on that, the dialogue is enable operate, it's retool re power or replace energy infrastructure that ceased operations or not end, enable operating energy infrastructure to avoid, reduce, utilize or sequester air pollutants or GHG emissions. So the bottom line is just that or and that second category provide a substantial amount of flexibility for really cool projects that I know, and we'll talk a little bit more about this. But just in the market, we know there's projects like net zero ports out there that are just really hard to pull together without a loan guarantee. But I think this is the first time that there's some flexibility in government programs to really deal with these projects comprehensively. So I know I'm really excited about the opportunity that this brings.

I think this is the first time that there's some flexibility in government programs to really deal with these projects comprehensively.

Jigar Shah: I think that's right. And I also think that the cast of characters here can be quite broad, right? So I think there's a lot of folks who started thinking about this as the electric utility companies using this to do securitization of coal debt and things like that. But I think you're starting to see a lot of interest from independent power producers who have, you know, 15, 20 year old gas plants. They're trying to figure out the next move for a lot of those plants. You also see a lot of renewable energy companies aggressively going out and buying, operating coal and natural gas plants to get the interconnection point for those facilities and then filing to restate the use of that interconnection to do solar plus storage or something like that. So I think that qualifies. And so there's a lot of different types of people who could be applicants, you know, under this program, not just electric utilities.

Taite McDonald: And I just couldn't agree more. And that's one of the main points I really wanted to convey in this dialogue today, because the I think developers and the industry is so used to thinking LPO does one thing, but what's so important about this legislation is it really does open up the loan program to operate like the Green Bank that we were always hoping that it could just under a whole new category that yes, has some parameters, but it's not overly prescriptive by any stretch of the imagination. So another thing that I really wanted to touch on today and Justin, going to turn it over to you to jump in finally. But one of the things that Jigar, you and I talk about a lot is companies being ready to take on debt and projects being ready to integrate debt when they come to the loan program. I think over the past year of dozens of applicants, many and we've told, "Hey, you're not quite ready yet, come back in a little bit," even though we're trying to get as many in as possible. I know what we consistently see is companies that just haven't even started the dialogues about bringing on debt. So Justin, could you talk a little bit about especially given your Generate role in supporting Jigar and the transactions that Generate was able to do over the past eight years or so, could you talk a little bit about what it takes and what companies should be really thinking about from bringing on debt and starting to approach these programs?

I think developers and the industry is so used to thinking LPO does one thing, but what's so important about this legislation is it really does open up the loan program to operate like the Green Bank that we were always hoping that it could just under a whole new category that yes, has some parameters, but it's not overly prescriptive by any stretch of the imagination.

How to Approach Loan Guarantee Programs Effectively

Justin Boose: Sure, sure. Thanks for the opportunity. So my practice really is on the development and finance side, you know not so much in the policy side. And in this role, I see developers of a very diverse array of technologies and a very broad range of sophistication. So I sort of look at this whole program a little bit as a boomerang, right? Clients come to me sort of trying to learn more about the program and the financing opportunities available, and I'm able to refer them to Taite and our team in D.C. to kind of work through, you know, whether it makes sense for them to move forward. And then at that point, my job is really to kind of help put them in a position to succeed. So for me, the application process is really akin to a job application process, right? The three most important things are your preparedness, your credibility and doing your homework. So it's everything from, you know, articulating a distinct purpose for the use of funds, you know, preparing an appropriately sophisticated financial model to support the ability of the project to repay the loan.

The three most important things are your preparedness, your credibility and doing your homework. So it's everything from, you know, articulating a distinct purpose for the use of funds, you know, preparing an appropriately sophisticated financial model to support the ability of the project to repay the loan.

Taite McDonald: Exactly. I think that's something we see all the time, is making sure companies have the model appropriately prepared, making sure contracts are moving to financeable. I mean, I know we're not always getting there in the our space, but at least you're at least moving the needle. I mean, our constant dialogue is we have to move the needle as far as we can to make sure that we can get to the reasonable prospect of repayment for the loan program.

Justin Boose: Right. And it's really a credibility component. I see developers all the time, each in an equal place of maturity, but one vastly more financeable and credible to the marketplace than the other. And it comes down to your documentation, having the right look and feel, having sophisticated transaction counsel who knows what financing markets generally and the LPO program specifically are going to look for. It's having a data room, having all of your, you know, your inputs and outputs covered, you know, under binding, articulable, enforceable agreements. And I think, you know, I think that's where a lot of folks with great technology who maybe have a strong engineering background and not a strong finance background are being held back and really need to just tap into the right advisors and start early on with the best practices of, you know, documenting and papering transactional assets, financial modeling and everything else that's going to be looked at once they come out of the application process.

And it's really a credibility component. I see developers all the time, each in an equal place of maturity, but one vastly more financeable and credible to the marketplace than the other. And it comes down to your documentation, having the right look and feel, having sophisticated transaction counsel who knows what financing markets generally and the LPO program specifically are going to look for.

Jigar Shah: Well, I mean, but I'd say with respect, Justin, I think one of the biggest challenges that we have, as you know, is when you take the world's top developers, who you guys clearly work with, they're not making decisions based on the availability of loan programs office debt. Right. And so they are playing it safe and only doing deals that they think they can get commercial debt for, which they're also underperforming on their return on equity for. And so part of what we need to do at the loan programs office is be trusted enough by those developers that they will actually do things that deliver much higher equity returns for them, but are dependent upon us being around and available to them to be able to realize those returns.

Taite McDonald: So funny, I actually had that conversation this morning about how the best thing about the IRA is it shows that the loan program will be there. Of course, there's a lot of work ahead of us. We've talked a little bit about that already. There's a lot of work ahead of us to make sure it stays consistent and available in that perspective. But it really does open up a whole new opportunity for the market now that the foundation is laid and the loan program is becoming what it was always intended to be. I think it's really important for those developers to continue to start to trust in the loan program, go through the process, because if you don't start the process, you can't get the loan.

Jigar Shah: No, I get it. But I mean. But they're not there yet. Like I talked to one of the top developers in the country this morning and, you know, they're like, well, but Jigar, are you sure that the NEPA process is going to take one year and not three years? Are you sure that this Buy America provision is not going to apply to the loan programs office? Are you sure that this is going to happen and that is going to happen? I mean, they are genuinely nervous about using our program. And as a result, there are projects that they're looking to just not do because the numbers don't pencil unless our program is there. Right. They're not going 100 percent equity finance, something at, you know, 8 percent or 7 percent returns.

Taite McDonald: I want to emphasize the importance of you coming in, the industry all working together, the communication to Congress on the importance of the program. Clearly, Congress is understanding it, but we all just have to continue as an industry as well, right?

Hesitancy to Make the LPO Leap 

Jigar Shah: Yeah, but I think we've got to press the flesh. I mean, I don't know what you think, Justin, but, like, I feel like. I feel like we can't take it for granted. Like, I think the IRA is awesome, and it's the right signal at the right time. But there's a lot of people I talked to who are still just plain lazy and they're not getting into advanced geothermal, they're not getting into low impact hydro, they're not extending their development chops into some of these other sectors. They're just doing the same old sort of solar and wind projects that are oversubscribed. They're waiting three years in interconnection cues, they're not reaching for the next innovative thing.

But there's a lot of people I talked to who are still just plain lazy and they're not getting into advanced geothermal, they're not getting into low impact hydro, they're not extending their development chops into some of these other sectors. They're just doing the same old sort of solar and wind projects that are oversubscribed. They're waiting three years in interconnection cues, they're not reaching for the next innovative thing.

Justin Boose: I 100 percent agree, they're taking the safe bet, which is why I think that the outreach that you're doing on behalf of the program office to really articulate the broader goals of the program and the broader reach of the technologies and project types that should be eligible, you know, is doing what it needs to sort of signal to the market to bring, you know, to dig deep to go further, you know, to be more aggressive in goals and in, you know, kind of exploitation of technology and really just kind of moving the industry where it continues to go and it needs to continue to go to sort of get to net zero and to bring in and harness every possible available resource and, you know, kind of resource repurposing that we can. And I do think that the recent legislation and the sort of the demonstration of the stability of the program and the likelihood of the funds being there, is also a big piece of it. And I think that story is being told well and that the momentum in Congress and everything else going on in the industry you know backing it supports that story.

I do think that the recent legislation and the sort of the demonstration of the stability of the program and the likelihood of the funds being there, is also a big piece of it. And I think that story is being told well and that the momentum in Congress and everything else going on in the industry you know backing it supports that story.

Taite McDonald: I'm hearing you guys say this instead of me, for once.

Jigar Shah: I mean, the other challenge, honestly, is that there's just a lot of, there are a lot of private sector folks who have allowed themselves to sort of get jaded. And, you know, you hear it all the time. They're just like, oh, we're not going to get into a sector that depends on the government. And at this point, all 25 sectors depend on the government. That's how this works. Like we're in the era of the industrial strategy.

Taite McDonald: It's where we were going to end up regardless, let's put it that way. It's something I've always thought about. It's why I'm at Holland & Knight with the platform we have because it's where we are going to end up in that sector.

Jigar Shah: Yeah, but we got to get folks from the top telling their teams that it's okay to show weakness. Right. The only way for this to work is for growth companies and institutional infrastructure investors to tell the government: "Here are the three risks we're just absolutely not going to take." The government has to take those risks or figure out how to de-risk it for us. And right now, I would say across the 25 sectors that we're accepting applications for, it takes us seven rounds of conversations with these applicants to get them to come clean on what that risk sharing needs to be. We're not having very good conversations across the industry for these sectors that are not yet mature, whether it's carbon capture and sequestration, whether it's hydrogen, whether it's CO2 pipelines through the SIFIA loan program that we're administering. You know, I think there's a lot of people out there that I think are just showing false bravado. And internally, their investment committees have not approved final notice to proceed on these deals. And unless they come clean with what they're really concerned about, a lot of these projects are going to end up, you know, like failing to launch.

Taite McDonald: Yeah, well, and it's not knowing how to communicate with the government in a way that helps both sides, that is applicable for both sides, which I think is it's why we're at such an inflection. And it was such an amazing inflection point. And this is where I will put in a plug for us, because this is what we do. This is what we know how to do. I spend just as much time talking to boards as you probably do at this point, Jigar, and getting boards comfortable with everything and moving projects through, but then also speaking to the government in a way that translates the needs of the industry to the government to move the projects through. Because, you know, we have to have, those conversations are occurring all the time in negotiations. But the bottom line and I know we're a little late on time, and I want to get to our final question, but the bottom line is, like, that's what we are here for and that's what we all have to continue to do together. And I think this is an open invite. We do these things to show there's an open invite for folks to come to you and continue to pose these problems and find counsel to help you get through them.

The bottom line is, like, that's what we are here for and that's what we all have to continue to do together. And I think this is an open invite. We do these things to show there's an open invite for folks to come to you and continue to pose these problems and find counsel to help you get through them.

Jigar Shah: Yeah, I totally agree. I mean, having a strong ecosystem for our program is super important because a lot of these folks aren't going to want to bring this expertise in-house. They're going to want to hire someone to help them get through this process.

Looking Ahead

Taite McDonald: Well, and we all know I'm going to be here. I've been here before it was cool again. So but the bottom line is we just have to keep on moving and we're not going to give up on it. But on that point, and I've pulled all my colleagues along throughout the years. On that point, in closing, what are you guys most excited about? I know I was thinking about it this morning. I'm just really excited finally to get some of the deals we have through the pipeline that are kind of closer to us, like American solar manufacturing back again and the SAF projects finally done that have been sitting out there for a decade and the first few big hydrogen projects. But what are you guys most excited about?

Jigar Shah: Yeah, look, I think we spent the better part of the first 16 months really building the foundation of the office and making sure that our policies and procedures were tight and that all of our ecosystem partners within the government actually could handle the volume that was coming in. Right. I mean, when you first started talking to the office of the CFO and OMB and Treasury, etc., I mean, even, you know, thinking about doing three deals a month was not something that people were staffed for. Right. And so I think, you know, getting into that rhythm is something the government takes some time to get to. And I think we spent the time to get everyone there in a way that was comfortable and I think is durable so that private sector folks can depend on the fact that we are not just, you know, doing this with duct tape and baling wire, but we actually helped to build a lot of that capacity back into the government to process these loans. I think the next piece of it is to figure out how we get LPO to be dependable. I mean, I think as we know, you know, part of that is making sure that you guys have a good ability to handicap projects coming in. Right. And that there is there are no surprises. Right. Like surprises causes everyone problems. And we've got to get to the point where there are no surprises and we're not there yet, let's be honest. And so we've got to figure out a way to communicate better with you about where the lines are for the loan programs office and making sure that, you know, we're not jerking people around by giving them false hope that, you know, their projects are going to qualify for the office. And then, you know, the last thing for me is making sure that people are making A round and B round investments into companies that depend on the loan programs office being there for them to cross the valley of death on the other side. Right. Like today, many of those companies are not getting A and B round investment because people don't think there's an ability to get debt for their first of a kind project or their second of a kind project. And I think given the track record that we've had this year and the one that we're going to be building throughout the end of the year and then into next year, I do think we're increasingly finding ourselves listed in reports from the Prime Coalition and ITIF and other organizations that are saying, "Oh, you know, as part of the innovation cycle, the loan programs office fits here," and that is allowing corporate investors to feel more confident to invest in deep tech and hard tech, which is what we need to be able to decarbonize our country by 2050 and our electricity grid by 2035. So that's where I'm headed because I think that we've got most of the technologies we need to reach those goals. But the government has to be really firmly in control of figuring out how to work with the private sector on accomplishing these industrial strategy goals in an absolute fashion.

 I think we spent the time to get everyone there in a way that was comfortable and I think is durable so that private sector folks can depend on the fact that we are not just, you know, doing this with duct tape and baling wire, but we actually helped to build a lot of that capacity back into the government to process these loans. I think the next piece of it is to figure out how we get LPO to be dependable.

Taite McDonald: I couldn't agree more. Justin?

Justin Boose: Yeah, and I guess for me, kind of given where I sit at the intersection of the evolution of different technologies across the clean tech sector and the private sector backing them, it's just, you know, kind of helping folks understand how their technology or project may fit in with the program mandate, what they need to do to get it there. And again, to Jigar's point, shifting the mindset from, you know, kind of telling a narrative where everything, you know, is rosy, you know, as the boat's about to go over to the rocks. Understanding that the DOE is looking at this differently. It's not a entirely for profit driven program, but it's really a program to encourage the development of these projects and technologies. And therefore, to your point Jigar, going in with the problems that need to be solved rather than answers that may not ring true, you know, really being the pathway to success and getting through commitment and funding.

Jigar Shah: Totally agree.

Taite McDonald: And in closing, I'll just say, because we spent so much time talking about this is a celebratory discussion, but we had to spend time talking about what it's going to take to make it sustainable and continue throughout the next decade and beyond. And the one thing I will say for companies out there, just in closing, a little goes a long way with congressional representatives. We really rebuilt this program piecemeal with the voices of many. I mean, I know our letter for the $30 billion authority expansion, we ended up getting $40. Our letter was $30 billion and $2.6 billion of credit subsidy costs. But we have 30 or 40 clients on that letter. And it's by doing that and signing on to those letters that we were really able to turn this ship with a lot of the NGOs, too. So just in closing, for companies, a little really does go a long way. Anything else in closing? But thanks, guys. This was a great conversation and I'm just so excited to continue them because there's just so much opportunity ahead of us.

Jigar Shah: No, thanks for having me on. And I hope that people are hearing loud and clear that we want people's feedback. And so, you know, whether you've had good experiences or bad experiences with the office, if you think your technology should have qualified but didn't, you know in previous iterations, let us know so that as we write these new rules, we can make sure we do it in a way that accommodates all these comments and feedback.

Taite McDonald: Can't stress that enough because the program really is listening and working with us on all the transactions we have. And we've definitely been able to do things that a few years ago we wouldn't be able to do just by making sure that everything's defined right. So, Justin, anything else in closing?

Justin Boose: No, I think we covered it all. I think, you know, we're available on, you know, both the program application side and the financing side to kind of help folks who need to figure out how to approach an interface with the program and just kind of encourage folks to reach out.

Taite McDonald: Thank you, guys. Thank you for joining us today.