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294   Chapter Thirteen


                                                                Simple
               Tax Scenarios                     NPV     IRR    Payback
               Linear depreciation and no tax   $(4.46)  5.5%     12
               incentives
               5-year accelerated depreciation with  $(4.88)  4.9%  13
               no carry over of tax benefits
               5-year accelerated depreciation with  $(1.66)  6.9%  10
               tax benefits utilized
               5-year accelerated depreciation + PTC  $2.58  9.8%  8
               with tax benefits utilized
               5-year accelerated depreciation + ITC  $4.22  11.5%  7
               with tax benefits utilized

             ∗  NPV is in millions.
              TABLE 13-11  Financial Performance Parameters

              of tax-equity partnerships in which an entity that generates sufficient
              taxable income in an unrelated area (like banking, insurance) owns a
              majority stake in a wind project. Such a tax-equity partnership is able
              to “monetize” the tax incentives. After most of the tax benefits have
              been realized, then the majority ownership of the project flips to the
              project developer. Through such a scheme, PTC or ITC are monetized
              in the project.


        Financing and Structure of Wind Projects
              There are numerous methods of financing and structuring a wind
              project. The methods may be generalized into two broad categories: 10

                  1. Corporate structure. Large utility companies, energy compa-
                    nies, and large wind development companies from Europe
                    are examples of this structure. Financing is done primarily
                    through internal funds and the tax benefits are used inter-
                    nally to offset income in the project portfolio.
                  2. Tax equity and flip investors. In this corporate structure, tax in-
                    vestors provide a fraction of the capital and, in return, get
                    tax benefits. After much of the tax benefits have been real-
                    ized and a predetermined IRR has been achieved for the tax
                    investor, the ownership of the project flips from the tax in-
                    vestor to the project developer. The reason for such a struc-
                    ture is to bring in capital to the project from investors that are
                    able to utilize the tax benefits. This structure has numerous
                    variations:
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