SECTION 11. TAXPAYER

RELIANCE

To the extent reliance statements in Notice 2023-38 and Notice 2024-41 conflict with this notice, the reliance statements described below shall control.

Taxpayers may rely on the rules described in sections 3 through 6 of Notice 2023-38 for the domestic content bonus credit requirements for any Applicable Project, the construction of which begins before the date that is 90 days after the date of publication in the Federal Register of proposed regulations on the domestic content bonus credit requirements.

Taxpayers may rely on the two modifications ¹⁴ of Table 2 in Notice 2024-41 for any Applicable Project the construc

(c) All of the steel piles and steel reinforcing products in foundation are manufactured in the United States and meet the Steel or Iron Requirement.

(d) Two sets of PV modules are used in the Applicable Project B. One set has a capacity of 60 MWdc and are PV modules manufactured in the United States that incorporate c-Si PV cells and wafers that are manufactured in the United States, with the modules’ remaining Manufactured Product Components, as identified in accordance with the table in section 5.05 of this notice, also manufactured in the United States. The remaining set, with a capacity of 40 MWdc, is manufactured in the United States with domestically produced PV cells using foreign wafers and domestically produced front glass. None of the remaining set of modules’ other Manufactured Product Components are produced in the United States. None of Applicable Project B’s PV inverters are manufactured in the United States or have any U.S. Components.

(e) The PV trackers used in Applicable Project B are manufactured in the United States and have seven categories of Manufactured Product Components (torque tubes, structural fasteners, drive system, dampers, actuator, controllers, and rails) of which a portion of the torque tubes are manufactured in the United States. The PV trackers are associated and directly integrated with all the PV modules used in Applicable Project B. The torque tubes manufactured in the United States are the only torque tubes associated and directly integrated with 80 MWdc of Applicable Project B’s PV modules. The remainder of torque tubes and other PV tracker components are not manufactured in the United States. The PV trackers are Non-U.S. Manufactured Products because some of their Manufactured Product Components are not produced in the United States.

(f) Applicable Project B’s steel or iron products identified in the table in section 5.05 of this notice meet the Steel or Iron Requirement. The Taxpayer makes a valid election to use the associated cost percentages for ground-mount (tracking) with domestic c-Si PV cells & domestic wafers. The Taxpayer is able to do so because a portion of the PV modules in the Applicable Project use domestically manufactured crystalline silicon cells that exclusively use domestically manufactured wafers. The table in section 5.05 of this notice identifies the torque tube Manufactured Product Component of a PV tracker of a PV system as constituting 8.6% of the total cost of Manufactured Products for this type of Applicable Project. The table in section 5.05 of this notice identifies the Manufactured Product Components of a PV module as constituting 69.7% (51.6%

• 4.7% + 4.7% + 3.0% + 3.0% + 0.8%
• 0.2% + 0.2% + 1.2% + 0.3%) of the

total cost of Manufactured Products for an Applicable Project that is a groundmounted PV (tracker) with domestic c-Si PV cells & domestic wafers, of which front glass accounts for 4.7 percentage points. In addition to these costs, the table in section 5.05 of this notice provides that the cost to produce PV modules for such an Applicable Project constitutes 3.7% of the total cost of Manufactured Products for such an Applicable Project.

Based on a nameplate capacity weighted average of Applicable Project Component categories and Manufactured Product Component categories identified in the table in section 5.05 of this notice, the total Updated Assigned Cost Percentage attributable to the PV modules of Applicable Project B would be calculated as: [(69.7% + 3.7%) x 60 / 100] + [(4.7%) x 40 / 100] = 45.9%. Based on a nameplate capacity weighted average (using the capacities of the Applicable Project Components associated with torque tubes), the Updated Assigned Cost Percentage attributable to the torque tubes of Applicable Project B would be calculated as: 8.6% x 80 / 100 = 6.9%. Applicable Project B’s overall Domestic Cost Percentage is: 45.9% + 6.9% = 52.8%. Applicable Project B satisfies the Adjusted Percentage Rule because its Domestic Cost Percentage of 52.8% exceeds the adjusted percentage that applies to Applicable Project B (40%).