Inside Summit Ridge's Fortnight of Tax Equity, Debt and Credit Sales

August 12, 2024
Inside Summit Ridge's Fortnight of Tax Equity, Debt and Credit Sales

Summit Ridge Energy has sold $40 million of solar tax credits to a privately held real estate company. On its own, that is a mid-sized credit sale. It was not on its own. In the two weeks before it, Summit Ridge had also lined up a tax equity investment and a $309 million term loan. Three different instruments in one fortnight say more about how community solar gets funded than any one of them does.

Key takeaways

  • Summit Ridge Energy announced on 9 August 2024 that it had secured $40 million through the sale of investment tax credits for the development of community solar projects in the US.
  • The buyer of Summit Ridge Energy's $40 million of investment tax credits was a privately held real estate company, and Reunion Infrastructure facilitated the transfer.
  • Summit Ridge Energy said it would use the proceeds of the tax credit sale to develop community solar projects for disadvantaged communities across the US.
  • Summit Ridge Energy, launched in 2017 and headquartered in Virginia, had a development pipeline of more than 2 GW and expected to have more than 600 MW of solar online by the end of 2024.
  • Enerdatics records 13 US solar tax credit transfers announced in 2024, of which nine disclose a value; among the six project-level sales with a value, Summit Ridge's $40 million is the second smallest.

How does selling tax credits differ from tax equity?

Selling credits is a cash sale; tax equity is a partnership. Under tax equity, an investor takes an ownership stake in a project and receives most of its tax benefits until it reaches an agreed return. Under the transferability rules introduced by the Inflation Reduction Act, a developer can instead sell credits outright to an unrelated buyer for cash, with no ownership changing hands.

The two suit different buyers. Tax equity has traditionally been the business of a small group of large banks and specialist investors, because it requires complex partnership structures. A straight purchase of credits is simpler, which opens the market to companies that have tax bills to offset but no interest in owning solar projects. A real estate company is exactly that kind of buyer.

Reunion Infrastructure acted as facilitator. Intermediaries of this kind match sellers of credits with corporate buyers and handle the diligence that makes the transfer safe for both sides.

Why did Summit Ridge use both at once?

Because they fund different parts of a large, staged portfolio. Leap records that on 26 July 2024 Summit Ridge secured a tax equity investment from Foss & Company for a community solar portfolio of about 91 MW in MISO, with the amount undisclosed. Foss is a long-standing partner: Leap records earlier Foss tax equity for Summit Ridge in 2021 and 2023, and Foss was also a buyer of transferred credits, as when it bought $118.5 million of Longbow's credits from Tokyo Gas.

On 6 August 2024 Summit Ridge then secured a $309 million term loan from lenders including Bank of America, Nomura, Prudential Private Capital and MetLife, for a portfolio of rooftop and community solar projects already in operation. Three days later came the $40 million credit sale, aimed at projects still in development.

Read together, the sequence covers each stage. Tax equity brings an investor into a defined set of projects. Term debt is raised against operating assets once they are generating. Transferable credits turn the tax value of projects under development into cash without bringing in a partner. A developer with more than 2 GW in its pipeline needs all three.

How big is a $40 million credit sale?

Mid-sized for a project developer, and small next to manufacturing credit sales. Enerdatics' data shows 13 US solar tax credit transfers announced in 2024, nine of them with a disclosed value. Three of the nine are manufacturing credits under Section 45X, led by First Solar's two sales to Visa of $645 million and $225 million. The other six are project-level sales, ranging from Ellomay Capital's $19 million to Recurrent Energy's $103 million from North Fork, with a median of about $59 million. Summit Ridge's $40 million sits second from the bottom of that group.

Only two of the six are for community solar. Twelve days after Summit Ridge's sale, Generate Capital sold $64 million of credits from 11 community solar projects in New York to KeyState Renewables. The other four are tied to projects in Texas and Oklahoma, such as the $80 million ENGIE sold to Schneider Electric from its Texas projects.

What does the deal signal for community solar finance?

It signals that transferability has widened the pool of capital available to small projects. Community solar portfolios are made of many sites of a few megawatts each, which can make traditional tax equity costly to arrange per megawatt. A buyer that simply purchases credits, such as a real estate company, does not need to underwrite a partnership for each site.

It also signals that the larger community solar developers were building layered funding stacks rather than choosing one route. Summit Ridge kept using tax equity with Foss, borrowed against operating projects from long-term lenders and sold credits from projects in development. Its later record in Leap continues the pattern, with a $305 million bank financing in September 2025, a $244 million tax equity investment in October 2025 and a further $150 million of tax equity from Foss alongside Apollo in August 2026.

Finally, the stated use of proceeds matters. Summit Ridge directed the money to community solar for disadvantaged communities. For a buyer of credits, that gives the purchase a social objective alongside the tax saving, which is part of what a non-energy company such as a real estate firm gets for its money.

Frequently asked questions

How much did Summit Ridge Energy raise from its tax credit sale? Summit Ridge Energy raised $40 million through the sale of investment tax credits, announced on 9 August 2024, to a privately held real estate company, with Reunion Infrastructure facilitating the transfer.

What will Summit Ridge Energy use the $40 million for? Summit Ridge said it would use the proceeds to develop community solar projects for disadvantaged communities across the US.

How does the Summit Ridge sale compare with other 2024 solar tax credit transfers? Among six project-level US solar tax credit transfers with a disclosed value in 2024, Summit Ridge's $40 million is the second smallest, against a median of about $59 million.

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