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Case Study: Preserving the Federal Investment Tax Credit for 22 MW of Commercial Solar

The Project

Philadelphia Green Capital Corp. (PGCC) partnered with Reinvestment Fund to provide two participation loans that enabled developers to preserve eligibility for the federal Investment Tax Credit (ITC) before new prohibited foreign entity requirements took effect. When both borrowers requested increases to their existing safe harbor facilities in late 2025, Reinvestment Fund invited PGCC to participate through specially structured subnotes funded with PGCC's lending capital lending, which is anchored by a $10 million loan from the Coalition for Green Capital (CGC) through the U.S. Environmental Protection Agency’s National Clean Investment Fund, and the Green Family Foundation. PGCC's access to low-cost capital from CGC allowed the subnotes to offer below-market interest rates, helping strengthen project economics while preserving access to the ITC. The participation loans supported two existing PGCC partners in the Solarize Greater Philadelphia program, Exact Solar and Capital Good Fund, and ultimately helped secure the tax credit for approximately 22 MW of small-scale commercial solar projects across Pennsylvania. Reinvestment Fund closed the primary facilities before the December 31, 2025 federal deadline.

The Results 
By preserving ITC eligibility, these participation loans helped protect approximately $75 million in planned clean energy investment across Pennsylvania. The financed projects include solar installations serving municipalities and small nonprofit organizations, sectors that often face significant barriers to accessing affordable capital. Preserving the federal tax credit improves project feasibility, lowers financing costs, and enables these organizations to move forward with critical clean energy investments. Collectively, the portfolio is expected to deploy approximately 22 MW of new commercial solar capacity while avoiding an estimated 22 metric tons of greenhouse gas emissions in year 1 and 517,086 over a 25 year lifetime, advancing Pennsylvania's clean energy and climate goals while demonstrating how PGCC’s mission-driven financing can respond quickly to changing federal policy.

Project Snapshot

Term: 36 months
Location: Pennsylvania
Project Type: Equipment Loan
Closing Date: May 21, 2026
Co-Lender: Reinvestment Fund