Ownership or PPA: the first decision for a tax-exempt campus
Before the Inflation Reduction Act, a school district could not use the federal investment credit at all, so almost every public school array was a PPA or lease. Elective pay changed that. Under Section 6417, states, political subdivisions (which includes cities, towns, and regional school districts), and tax-exempt organizations such as private colleges can elect to treat the Section 48E credit as a payment against tax, and receive a refund of the amount that exceeds their liability, which for most is all of it.
The credit itself follows the same rules as for any commercial owner: a 6 percent base, rising to 30 percent when the facility's net output is under 1 MW AC or when prevailing wage and apprenticeship requirements are met. Under the One Big Beautiful Bill Act (OBBBA, enacted July 4, 2025), solar facilities that began construction on or before July 4, 2026 are not subject to the 2027 placed-in-service deadline, subject to continuity rules. Facilities beginning construction after July 4, 2026 must be placed in service by December 31, 2027. For a campus that has not yet started construction, that date is the governing constraint on schedule. Details are in our guide to the Section 48E credit and SMART 3.0.
| Factor | Own, with elective pay | Third-party PPA |
|---|---|---|
| Upfront capital | Full project cost, from bonds, capital budget, or loans | None, or minimal |
| Federal credit | Received as an IRS payment after the return is filed | Captured by the owner and reflected (in part) in the PPA rate |
| Depreciation | No value to a tax-exempt owner | 5-year MACRS and bonus depreciation reduce the investor's cost |
| Operations risk | Institution carries it, usually through an O&M contract | Owner carries it; institution pays only for delivered kWh |
| State incentives and credits | Retained by the institution | Usually retained by the PPA owner |
| Lifetime value | Typically highest | Lower, but with no capital outlay |
A PPA still has a place. A taxable owner can use depreciation that a district cannot, and a district without bonding capacity or appetite for operating risk may prefer a fixed per kWh price. We model both against the same design so the committee compares like with like, and we cover the financing side in more depth on our commercial solar financing page.