Begin Construction Now: Getting Projects Bankable, Buildable, and Energized Before the Clock Runs Out

Another month, another wave of policy updates impacting your pipeline. What’s changed:

• For projects >1.5 MW AC, “begin construction” now means the Physical Work Test (not the old 5% path)
• Start qualifying work by July 5, 2026 to avoid the December 31, 2027 termination; keep a continuous program of construction (4-year continuity safe harbor)
• Qualifying work = on-site installation activities or made-to-order off-site manufacturing under binding contracts (not inventory)
• The 80/20 rule can re-qualify a repowered facility as new for ITC/PTC; confirm details with tax counsel!

Why this matters

Developers now succeed by verifiably starting real work fast and keeping it moving. Speed, certainty, and flexibility aren’t bonus points—they’re the difference between banked return and stranded capital. Planted Solar was built for this moment.

Begin construction, definitively (Physical Work Test)

Under OBBBA + Treasury guidance, the path is to start qualifying work by July 5, 2026 and maintain continuity—not to stockpile generic gear and hope. With upcoming FEOC rule clarification, it’s harder to know which components will qualify. And if your pipeline carries any development risk (whose doesn’t?), storing expensive components that may never go in the ground is a risky bet.

Physical Work

• On-site: Setting foundations/anchors, installing racking/structures, PV affixing operations
  
• Off-site: Made-to-order manufacturing under binding contracts entered before manufacture (not pulled from inventory)

According to IRS Notice 2025-42:

“...off-site physical work of a significant nature may include the manufacture of components, mounting equipment, support structures such as racks and rails, inverters, and transformers and other power conditioning equipment.”

‍

‍Planted’s edge

• Two standardized parts (up to 70% less steel) produced by high-volume U.S. partners—not long, fragile supply chains
• Project-specific, made-to-order fabrication under binding contracts so off-site work qualifies for Physical Work
• Pre-stage efficiently: Compact components minimize yard/warehouse footprint and mobilize quickly when sites are ready
• Not obsolete gear: Steel is durable; core hardware is compatible with shifts in module format and efficiency

How Planted helps you pass the Physical Work Test

• Binding purchase agreements tied to project IDs and dated fabrication milestones
• Made-to-order runs for foundations and racking (no inventory treatment)
• Optional on-site starter scope (e.g., initial racking/foundations)
• Continuity pack: Gantt, production logs, field logs—keeps you in the 4-year continuity safe harbor

Note for ≤1.5 MW AC: The 5% path remains; confirm specifics and aggregation rules with tax counsel.

From groundbreaking to energized—in months, not years

Most utility-scale projects take 12–18 months to commission. Planted’s platform can cut that in half with:

• Integrated site design → plan-to-field execution
• No grading → terrain-following arrays adapt to slopes/undulations
• Less soil disturbance → fewer permitting delays and stormwater impacts
• Rapid install → automated field machines + simple, reliable hardware

Result: More predictable schedules, lower risk, faster returns, and lower financing costs.

Retire development risks early, repower now

The best site is the one already owned, zoned, interconnected, and proven. If you have 5+ year old operating assets, now is the moment to create a redevelopment plan.

• Leverage existing approvals/POI
• Add DC + storage for step-change in yield and revenue stacking
• Satisfy tax rules in one integrated scope, confirm 80/20 compliance (new gear ≥80% of FMV) with counsel

Planted boosts repowers with high-density, terrain-adapting racking, made-to-order steel (Physical Work), and a continuity plan to keep you compliant and on schedule.

Key Dates

• Effective: Applies to facilities that had not begun construction under prior guidance before September 2, 2025
• Begin by July 5, 2026: Not subject to the December 31, 2027 termination (continuity still required)
• Begin after July 4, 2026: Termination applies to facilities placed in service after December 31, 2027

Better sites, fewer surprises

While other systems require flat, contiguous land and significant civil engineering, Planted’s design can deploy more energy on highly undulating or irregular plots, unlocking parcels near interconnects that would otherwise be dismissed. Planted arrays conform to terrain, reducing permitting friction and unlocking more viable sites.

That means every project with Planted can be built faster, and with lower costs, higher density, and more resilience. Today, more projects face setbacks at key zoning, environmental impact, and permit milestones that limit the physical footprint of their sites—large setbacks, bigger wetlands, limited viewsheds. All of this drives the need to use limited land more productively—without compromising returns.

Pipeline gut check: What to ask before you spend

• Can we begin Physical Work (on-site or made-to-order off-site under a binding contract) by July 5, 2026? (Inventory won’t count)
• When do we lock a fabrication slot (dated milestones help establish Physical Work)?
• Can we pre-stage components without compliance risk or obsolescence?
• Do our schedules survive permitting friction and supply variability?
• Does the project pencil if placed-in-service shifts?

Ready to move? Let’s talk.

The market is moving fast, and only the projects that build will bank the upside. You need Physical Work Tests you can pass, timelines you can trust, and a team that moves in weeks—not months or years.

Whether you’re looking to kick off Physical Work, break ground in 2026, or de-risk interconnects in challenging terrain, Planted is here to help you move quickly, safely, and confidently.

• Send a project for a 15-minute Physical Work screen → go/no-go, off-site vs on-site starter plan
• Reserve a binding fab slot → we’ll schedule a made-to-order run tied to your project ID (and line up optional on-site starter work)
• Get an IPP buyer intro → we connect qualified developers with active IPPs to help tee up a successful transaction with buyers who are ready to own Planted assets for the long term
• Request a Repower pro-forma plan → status-quo vs repower (PV+BESS), 80/20 sensitivity, NPV/IRR, continuity timeline

This is our collective moment. It’s time to deploy.

Compliance note: Planted provides commercial guidance; please consult your tax advisor on applying IRS Notice 2025-42 and 80/20 Repower rule to your projects.

Get in touch →