T-minus 24 hours to July 4: the 5-percent cost-incurred pool is being finalized through post-vacatur equipment purchase agreements, and the documentation quality gradient is steeper than tax-equity is pricing
The physical-work pathway on the July 4, 2026 begin-construction deadline has been the visible headline through Q2 2026. The quieter half of the safe-harbor pool sits on 5-percent cost-incurred, and the last-day filings on that pathway are running through equipment purchase agreements drafted after the June 6 vacatur of Notice 2025-42. Post-vacatur EPAs carry deposit, delivery, and 3.5-month-payment structures that the vacated notice would have narrowed. On the wire count, roughly 55 to 70 GWdc of the announced 216 to 240 GWdc solar safe-harbor pool is coming through the cost-incurred pathway, and the last-24-hour documentation stack is where the audit-quality gradient will concentrate. Tax-equity is not fully pricing the intra-pathway bifurcation yet.