In this illuminating episode, hosts Allen Hall and Joel Saxum interview David Burton, a partner at Norton Rose Fulbright law firm and an expert on U.S. tax policy for renewable energy. They dive deep into the intricacies of the Inflation Reduction Act and how it will impact wind projects, with David providing insightful explanations of production tax credits, investment tax credits, domestic content requirements, and more. With his extensive experience structuring tax-efficient energy deals and advising major corporations, David unpacks these complex new policies and delivers key knowledge that could save or make wind companies millions.

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Allen Hall: Welcome to the special edition of the Uptime Wind Energy Podcast. I’m your host, Allen Hall, here with Joel Saxum. And our guest today is David Burton. David is a partner at Norton Rose Fulbright, which is based in New York. David is an expert in US tax matters and has experience with structuring tax efficient transactions for renewable operations.

David was a managing director and senior tax counsel at GE Energy Financial Services, where he oversaw all the aspects for more than 21 billion in global energy projects. David, welcome to the program.

David Burton: Thank you, Allen. It’s great to be here.

Allen Hall: Okay. So the timing of this could not be better. And Joel and I were just up in Canada trying to explain to the Canadians what the IRA bill meant and why everybody is so confused as to what is happening in America.

So we thought we’d bring in the expert to help us with understanding the, all the tax incentives that are built in. Built up into the IRA bill. I don’t want to give you a couple of softballs to start with. How about that production tax credit? What is that in the IRA bill? And what does that mean?

David Burton: It’s $27.50 per megawatt hour for the first 10 years of production. If you transfer the project, the transferee steps into your shoes and does not get to restart the 10 year period. It’s a pretty powerful tax credit to get the 2750 megawatt hour. There are requirements you have to meet that we call the fine print that regard prevailing wage and apprentice requirements, which we can get into.

Allen Hall: That makes sense to me. That’s a really good explanation. I have not heard explained that simply.

Joel Saxum: That one’s easy. I like that one. I can follow that.

Allen Hall: All right. Investment tax credits. Let’s raise the heat up a little bit. What is an investment tax credit?

David Burton: The base of percentage for the investment tax credit is 30%.

Again, you have to comply with prevailing wage and apprentice to even get to 30%. And it’s a tax credit that accrues when the project is placed in service, basically operational. And it’s 30 percent of a tax basis. Which, you know, more or less is 30 percent of the cost of the project. Rather than having to wait 10 years, you get all, you get the tax benefit all upfront.

So, oftentimes the PTC may be a bigger gross amount but it’s over 10 years, so sometimes you’ll, you’re not opt for the ITC because it’s a better present value answer, but it’s just a question of math.

Joel Saxum: I want to touch one important thing here, and this is an important thing that I got from you, David, when we originally talked that I did not know.

And it’s huge for the tax code and huge for these all of this credits. You can only pick one. You do not get to choose an ITC for some stuff or like for, on a project for a little bit of this, a little of that, and then some PTC here and there. It’s like you either go PTC or you go ITC and you got to do the math to figure out which one you want to choose.

Allen Hall: Okay. Now let’s understand the little nuances here and what they apply to, because I’m not sure which one of, which of these protection or investment tax credits these apply to. Domestic content, which seems to be a large part of the IRA bill. And it seems to be oriented towards American steel and iron because most of the wind turbines made out of steel, what is the domestic content requirement?

And what does that mean? If I’m a company or an operator or developer trying to apply it?

David Burton: Well, first of all it’s not a requirement. It’s what we call an adder. So it’s a 10 percent adder. And so for the ITC, it’s 10 percentage points, so it would take you from 30 to 40. For the PTC, it’s 10%, so it’s 27, 50 times 110%, you know.

So it’s about $29 in change in in tax credit. So, so it’s additional opportunity for a bigger tax credit, but you could build your project with, you know, all Asian components of steel and still qualify for the base credit. It’s just an upside. If you qualify for it.

Allen Hall: And how do you show that you have the proper amount of domestic content?

How does that work when a when generator, the generator itself, the generator is made from parts from all over the world, typically. Do you have to go all the way down into the component level to determine what percentage of this thing this generator is made in America.

David Burton: Yes, but it’s even more complicated than that.

So the domestic content rules were written about as complicated as they could be and about as on user friendly as they could be. You know, the industry has commented heavily and is lobbying for them to be, you know, simplified or improved the U S treasury may or may not be inclined to do that.

So the first requirement is relatively straightforward. Which is that structural component have to be made out of U. S. steel and U. S. iron. So rebar in foundations has to be, you know, U. S. steel and has to be 100%. You can’t say, oh, I’m mostly U. S. steel, but I’ve got a little bit of Korean steel.

Has to be all U. S. steel. So that’s the first requirement. And so that’s the first hurdle. The second hurdle is that the manufactured components, have to be 40 percent U. S. And that percentage will escalate over time. But it’s currently 40 percent U. S. And what they did to avoid gamesmanship, but to make it very hard on the industry.

But they’re really focused on gamesmanship, but they said they were going to measure that 40 percent using the manufacturer’s Direct cost, which is U. S. Tax speak for the manufacturers labor materials, right? So they didn’t want people selling stuff at hyped prices or, you know, playing games. They said, okay, the most basic measure we could get to is, well, what did it cost to manufacture and labor materials to make this component?

And that’s what we’re going to test for domestic content and of those components, you need 40%. Now, if you have any imported subcomponent, uh, unfortunately, of certain subcomponents, unfortunately, you don’t get to count your assembly cost. So, even if you are assembling the component in Colorado, the United States, if you have subcomponents in that component, certainly subcomponents that are imported, you don’t get to qualify.

And that was more about solar. I’ll just give you quickly on that. That was really trying to ensure that solar cells are manufactured in the United States. So Treasury was concerned that people were going to build solar module factories and just assemble the modules here, but not make the cells here where the real technology is.

So they said, okay, if you do that, you don’t get to count your assembly costs. You have to count that as imported, even though it’s workers in Colorado putting it together. So that’s why they made it kind of onerous and similar concepts apply to wind components. Treasury put out a notice that for onshore, offshore winds utility scale solar storage tells us, you know, how far you have to drill down for each component.

Joel Saxum: It’s a tough thing here for me to understand. And we talked about this a little bit before is. These percentage rules are going to be based on labor and materials, but what, at what level of success do you think anybody’s going to get their vendor to give up their actual goods costs and basically show what their profit margins are to their clients to get these credits?

David Burton: Yeah, so far, there’s not been a whole lot of success in that. Some manufacturers are saying they’ll disclose to an accounting firm on a confidential basis when the accounting firm can write you a generic memo.

You know, that says, doesn’t give you the cost, but says, we’ve looked at it and you meet the 40 percent test you know, and we’re going to count in terms of trust us. So that’s another approach people are taking, but you need not just, but you also need to know what goes into the denominator of this fraction.

You also need to know the imported direct costs. So you need to go to Japan and Korea and China and say, Hey, look, I didn’t pay you any premium for this. You know, I’m not giving you anything to this, but would you just tell me, you know, what your profit margin is so I can put this in my denominator. And then those companies are obviously like, Well, you didn’t pay me anything more.

I never promised you this. I’m not doing it. You can get around that by just saying, okay, I’ll use my own cost. So I use my retail cost and I’ll put that in the denominator, but you have to have a lot of headroom, you know, in the fraction to have to work if you’re right at, you know, 40. 5%. And when you put in your your retail cost, it.

you know, it’s going to be, you’re going to fall under it. So you’d have to have headroom to that to work. So that’s the, you know, that’s the other challenge is happy to ask your foreign suppliers for their direct costs and they got nothing out of it. Right, so.

Joel Saxum: Yeah, we’re wading into the weeds now.

Allen Hall: Yeah. Okay. So, but I think that’s a really valuable thing to know at the moment because it does. There’s a lot of talk about domestic content, but when you get down to the reality, there’s somebody trying to figure it out, and it’s probably a room full of people trying to figure it out. It’s not as easy as it seems, and we’re going to keep driving deeper and putting the heat on here as we go.

What is low income community… Indian land incentives. What is that part of the IRA bill and why does it matter?

David Burton: I’m not sure it does matter that much for your viewers. You have for two reasons. First reason is you have to be under five megawatts of capacity to even qualify for that. So I, you know, I get the sense, you know, most of your viewers are utility scale players.

So, you know, they’re not even going to qualify. So then let’s say you are under 5 megawatts capacity and you meet this low income or Indian land requirement, you then have the right to apply to the Department of Energy and the Department of Energy will review your application and rank your application against all the other applications and make a recommendation to the IRS as to which projects should be granted an allocation.

So most of these credits, you just claim on your tax return. If you qualify. This one is competitive, right? So there’s a limited amount per IRS and DOE to allocate and it’s competitive process to apply for it. So, you know, even if you’re serving low income Indians on brownfields, you know, if you don’t if you don’t get the allocation, you don’t qualify for it. And, you know, there may be a project that’s, you know, more compelling to the Department of Energy that they rank higher. They prefer projects that are further along, right? So the further along your project are, the more likely it is to be built, the higher they rank it.

That’s one of the components. But they don’t want you to place the project in service until they give you the allocation. So you can end up in kind of suspended animation, whereby, yeah, like my project’s really far along. I’m definitely building it. Please give me the allocation. You haven’t given me the allocation yet.

Okay. I’m just stopping everything. You know, I’m just going to continue to pay on my construction loan, you know, continue to pay my ground lease, my insurance, I’ll just stop everything, not have any revenue and wait for you, Department of Energy to decide whether I do or do not qualify. So, there’s a lot of practical issues with it, but again it’s five megawatts and below.

So not an issue for the utility scale market.

Allen Hall: You touched on brownfields and the brownfield condition and incentives around brownfields came up in a discussion from Ørsted of all people. Ørsted was going to use it in, I think it was Sunrise wind farm at the, where they were planning to run the cable onto the, on land in New York was a brownfield location.

Well, the soil sampling they have done indicates it would be brownfield. And so therefore they could apply for, I think it was up to 10%. aNd does, so for basically running a cable through a plot of land, probably not even that big a plot of land, they get a bump up of 10%. Does, is that just the generic rules around?

Like if you run into a brownfield in any part of your project that there’s a 10 percent bump up in the payment?

David Burton: Brownfield is one of the energy community criteria or definitions. That is a 10 percent bump again, 30 to 40 or 110 percent of $27.50. Both ITC and PTC qualify. You don’t have to apply for it, you just have to put it on your tax return and get comfortable that you meet the definition and be ready to be audited at the IRS ops to audit you.

 The, that, that rule is for offshore wind, right? So. You know, they said, okay, we want offshore wind to be able to qualify for this, but brownfields and something in the middle of the ocean are kind of, you know, inconsistent, right? Not very common. Yeah. So they said, okay, they said, okay, you know, you look at your, you apply this by looking at the census track, you know, closest to where your project is.

So that’s what or said saying is that, you know, they’re building the project offshore of a brownfield. And so they think they should qualify. And that is, you know, in fact, you know, what the rule says, but it’s not like you can build a project in Nebraska and run a cable. You know, through you know, a toxic waste dump and say, Oh, I qualify.

Allen Hall: You know, it’s worth a try at this point, but okay.

So for our listeners that are not based in the United States Brownfield is a site that has been contaminated, not to the point where it’s not inhabitable, but there’s contamination in the soil that need to be reclamated, I guess. And when that happens it has limited uses. After that has occurred, so my guess in this particular case with Ørsted, that they would be forced to clean up the area in which they’re using or next to, so it sounded like Ørsted had done some soil drilling and sampling, so it sounds like they were talking about some sort of cleanup there.

But it, it sounded like a landing cable, it’s what it sounded like to me.

Joel Saxum: An export cable, yeah.

Allen Hall: Yeah. So, in the United States, in that particular condition, they’re going to give you a bonus for using a land that is being contaminated for another purpose. Putting a cable through it’s a really good concept, right?

Because it’s, it doesn’t involve any people being on it, but it’s still useful land. So there’s the incentive. Now, okay, so that’s the foundation. In wind, where are Operators, developers going at the moment, are they headed towards PTC or ITC for the most part, or what’s your feeling on that?

David Burton: So the rule of thumb, and it’s just a rule of thumb, it’s not a hundred percent true, is that onshore wind is PTC and offshore wind is ITC.

And that’s because onshore wind is relatively low cost of all the improvements in the technology and the construction and the efficiency. Much higher efficiency than it used to be. The capacity factors have gone up. And therefore you do the present value of a 10 years of PTCs and you say, okay, that’s greater than 30%.

The map tells me I want PTC. Offshore wind. It’s obviously very expensive to build because you’re constructing it in the ocean, and you’ve got all those challenges and very expensive equipment, and you got to transport it all out the middle of the ocean, and there’s limited number of vessels that can do that and all those good stuff.

Right? So for offshore wind, it tends to be that it’s so expensive that the ITC is the better option. And that’s what the sponsors are planning to claim. But on a project by project basis, it could be a different answer.

Allen Hall: So on offshore, if they’re going for ITC, that then affects what they’re asking for in terms of, uh, purchase price agreements, the PPAs, right?

On onshore, it’s the prices are sort of PPA plus PTC that’s how they tend to look at the business case, right? Right. So on offshore, then it’s ITC plus tends to be larger PPAs because like you’re explaining, it’s just sort of a difficult environment. Okay. That explains a lot about what’s happening with the developers off the coast of New York at the moment.

Now, what are energy tax credit transfers? And Joel and I have seen a number of big press releases about this energy tax credit transfers and how there’s a new financial instrument to. Transfer future PTC. To to or to buy, to swap that for current value. Is that present value is that what it is?

Joel Saxum: And there’s a commu, there’s a communication kind of guff there. And I think in the industry, ’cause a lot of people are reading this, not having an economic or legal mind, and they see like tax equity financing and PTC swaps and everybody kind of assumes it’s all the same thing. That’s, oh, that’s just how they finance the project.

But nobody knows or I’m not gonna say nobody knows, but a lot of people are. They just kind of blanket over it and they go yeah. They’re financing the project that way. But can you give us an outline of the difference between tax equity financing and people actually selling the PTC revenue and some of these things that we’re seeing in the news?

David Burton: Sure. Sure. So for a hundred years, the U S federal income tax law said you cannot sell tax credits. And when you did A structured kind of cutting edge transaction, what you would worry about is that the IRS would come in and say, Nope that’s not an equity investment. That’s actually a sale of tax credits.

You’re not allowed to sell tax credits. You lose. Right. And that was the law of the United States for a hundred years. Right. In the, in and that led to tax equity whereby through partnerships and sometimes leases. We were able to transfer much of the tax credits to a relatively passive financial investor who contributed cash upfront in exchange for being allocated those tax credits.

But it was, it’s still a pretty complicated transaction. You still have to deal with hundreds of pages of documentation. You still have to take some project finance, operational risk. It’s still an ongoing investment. You know, it’s a multi year very long investment. And so there was a limited universe of tactical investors and it tended to be big banks, some insurance companies, some corporates like GE and Berkshire Hathaway but, you know, really kind of the most sophisticated go getting kind of, public companies out there that had teams of people lawyers, accountants, engineers underwriters figuring out this stuff and many companies were just like, yeah, that’s not our core business.

We don’t want to learn project finance. We don’t want to learn any more tax law. We don’t want to read 300 pages of documents. You know, we know it’s profitable, but not for us, right? So there’s a limited universe. So then Congress said, we’re going to subsidize our clean energy and deal with climate change through the tax code.

But there’s not enough tax equity investors to monetize all these tax credits. We need something else. The first proposal was what we now what’s called direct pay, whereby you could just go to the IRS and say, I qualify for these tax credits, but I don’t owe any tax. Please cut me a check, you know, a hundred cents of a dollar for these tax credits.

Senator Manchin and others said, oh, that’s too much government involvement. We don’t want the government playing that role. We think this should be more private sector driven. So to get Senator Manchin’s, you know, tie breaking vote on board, they said, okay, we will shift towards transferability whereby the credits can be sold

to corporations banks, insurance companies, et cetera for cash and just a simple sale. So it’s, you know, you call it a financial instrument, that’s a little bit of an overstatement. It’s really just a bill of sale. It’s not that different than the bill of sale you used to buy and sell a car, you know, so you want to go buy a new Ford.

It’s a bill of sale, right? It’s the same kind of thing right now. It is. It is, you know, 10s of pages of documents as opposed to 300, maybe 20,30 pages of documents. So it’s more than a bill of sale for a Ford, but that’s basically, you know, that’s basically what it is. It’s not a lease. It’s not a partnership.

It’s just a. And it’s cash in exchange for tax credits. You don’t have any equity investment in the project. You’re not a member of the project. You’re not voting on whether or not to, you know, buy a new inverter, you’re, you’re not paying the property tax and it’s not doing any of that stuff.

You’re just buying the tax credits, extremely passive and we are seeing the market for that expand from the traditional tactical investors. We are seeing parties who. You know, pharmaceutical companies entertainment companies, retailers who pay a lot of tax have a savvy treasury and tax department saying, yeah, like, we’d rather pay 90 cents of a dollar than 100 cents of a dollar prior taxes.

We don’t have to have an ongoing investment. We don’t have to invest equity. We don’t have to deal with complicated accounting issues. You know, let’s do this. We are seeing it expand. But again, everybody wants to wants a profit, right? So no one, you know, nobody’s going to pay 100 cents of a dollar.

So it actually means that it costs the U. S. Treasury the same amount. It’s still a dollar of tax credit, but the developers only put a, you know, whatever, 90 cents in its pocket. While if they did direct pay was they don’t qualify for mostly they get to 100 cents on the Dollar so. Manchin is taking you know ten cents and away from developer to put into new projects and giving it to these corporations by tax credits. Which you know is work for me and I don’t complain about it but I’m not sure it’s the right. You know, the ideal policy from a climate change perspective.

Joel Saxum: Yeah, because I mean, the companies that do this are engaged within that trade basically market, they could take that capital.

They get up front, say a developer gets some cash up front for their future PTC funds in the grand scheme of things. They could take that money and invest it offshore. If they wanted to, right? It could be a like a CIP COP type. Are they doing some work here? Yes, but they have a large portfolio in Taiwan or offshore Japan or something like that.

And that money that’s a tax benefit within the states could actually be used to spur on renewable energy transition offshore or elsewhere.

David Burton: Well, it’s not so easy to get the money out of the U. S. without triggering withholding tax. So. I mean, you know that the U. S. tax law does, you know, is savvy about that.

So I’m not terribly concerned about the proceeds going to develop, you know, offshore wind in Japan. You know, and so, that’s not such an easy thing to do.

They’re more likely to leave the money here.

Joel Saxum: You know, there’s one other thing I wanted to kind of touch on here from competitive versus non competitive standpoint.

Now we talked PTC, we talked ITC, but there are other things in the IRA bill that we’ve, we spoke about offline. And one of them being the 45X and 48C. And then the idea that some of these are competitive, some of them are non competitive. Can you touch on that a little bit?

David Burton: Sure. So 45X and 48C are both to stimulate manufacturing of energy components, right?

So they’re not for projects. They’re not for, you know, Nebraska wind ABC project, right? It’s it’s for a factory, right? It’s for a factory.

Joel Saxum: Building a vessel or something like that.

David Burton: Maybe building a vessel. So for 48C, it’s kind of broad. DOE has some discretion as to how they grant it.

48 C is an investment tax credit again, right? So it’s money up front a percentage of your cost. And it does qualify for some of the adders, not all the adders, but some of the adders and it’s competitive. So you have to apply to the Department of Energy. There’s a limit as to how much the Department of Energy can allocate.

Congress put a cap on 48 C and the Department of Energy has been accepting applications is reviewing them. And we’ll rank them and then, you know, allocate based on how much capacity they have going down their list, giving it to what they perceive to be the best projects. And what they think of as the best project is kind of similar to what you said before. Both you know, impact on climate change or importance for like, climate change, but also the likelihood of it getting built, right? You could have like some genius solution, you know, build a new widget, but if there’s a 1 chance in 1000, you know, it actually gets built deal. DOE’s probably not going to want to fund it because they’re going to say, we’d rather have something more likely.

So, so that’s 48. H C. And then there’s 45X. You can’t do both. It’s either or. 45X is a production credit based on you know, making components. Making blades. Making modules. Making batteries. Each component has a different amount of credit that it qualifies for. And you get it for you have to make it and sell it to an unrelated party, right?

So you can’t sell it to your subsidiary. You have to sell it to an unrelated party. Right now, there’s lots of interesting negotiations going on in the market about how manufacturers and their customers share that benefit. Right? And both of these credits qualify for direct pay.

So, for both of them, you can say, oh, I don’t know any tax. I’m just going to go to the Treasury, the IRS say. I don’t earn any tax. Please cut me a check for 100 cents of a dollar. And you can do that. So it’s very clear that you can capture the benefit, and so then some customers are saying, oh, well, manufacturer, you’re going to get this big, you know, check from the IRS, you know. So therefore I want a lower price because you’re going to put this money in your pocket and that’s a windfall for you.

And I want a lower price. Manufacturers say no, we’re just barely getting by, you know, this is saving us, you know, we, we need this. You know, you’re making all this money, you know, leave us alone, let us keep it. That’s an ongoing discussion between the manufacturers and their customers.

Allen Hall: That same relationship though happened between New Jersey and Ørsted, right? On the ITC credits that they, the state of New Jersey smelled money and said, Ørsted, you owe us that. And that’s what happened in simplistic terms, right? Okay. All right. So it sounds like it’s happening even at state levels, not company to company, but even sort of bigger players.

David Burton: Everybody’s making sure their counterparty is not getting a windfall and everybody else at and also at the same time having their own handout and say, you know, I need this to survive, please, you know, that it’s not a windfall. So everybody wants a piece of it.

Allen Hall: Okay. So, I Want to just take it one, I guess one level up, which is there’s a lot of the details of the IRA bill.

They get thrown to the treasury department and the IRS. That they actually write the code that the manufacturers, operators, developers have to follow. And there has been a number of news articles from developers saying we don’t know what the IRS ruling is. So we’re not really sure what the percentage is and what we’re going to get.

So we’re still trying to get clarity there. Is, are some of these things going to become clearer in the next 6 to 12 months as particularly offshore gets developed?

David Burton: So, treasury has done a good job meeting the timelines to get the guidance out. And we now have guidance, at least proposed guidance on everything except for 45X, again, that manufacturing production credit we just talked about, and for hydrogen, 45D, the hydrogen credit which is, In a quagmire within the government because different departments within the government have different views as to whether, you know, you should be making it better for hydrogen or for renewable energy project owners.

So, there’s a, there’s an arm wrestling match going on over that. And they missed the statutory deadline congress gave them to get those rules out. They just said they couldn’t do it. And they haven’t resolved it yet. So who knows when we get that guidance that we could be tomorrow.

They could. They could settle their internal disagreement, or it could be, you know, years so, but that’s hydrogen, which is not your, you know, audience 45 X. We’re still waiting for, you know, the other thing we’re waiting for, which does matter, particularly to offshore wind is in 2015. So, 8 years ago the IRS and treasury put out a notice saying we have these really old investment tax credit regulations from the 1980s.

The technology has changed. The law has changed. Market practice has changed. We need to update them to reflect new technology, et cetera. So that was right at the end of the Obama administration. They they asked for comments. The industry set in, you know, thoughtful, detailed comments. Trump won the election.

Trump said, nope my IRS is not spending time on this, you know, bury that in a drawer somewhere and forget about it. Which they did and then Trump lost the next election. We get Biden. Biden’s like, yes, I want you to do this. This is great. Please, you know, work on this. Then we get the IRA, which changes the rules again.

So, like, okay, we have to go back and revisit some of this and tweak some of it and rework it. The iRS and Treasury are saying that we will get those regulations. They’re saying informally, Yeah, We should get those regulations by the end of the year, but it’s been 88 years. So, you know, who knows? But there are a number of issues that are important to the offshore wind industry. Pending in those regulations and that they, those will answer some questions that the offshore wind developers have been holding their breath about.

Joel Saxum: So from the industry, we all need to sit here and cross our fingers that we get these done before the next election cycle so they don’t get pushed off again.

David Burton: Yeah. It’s a political football. Absolutely.

Allen Hall: David, this has been really insightful. Joel and I have learned a tremendous amount about tax law the United States, which is a shocker for an engineer because that’s not something we

plan on doing anytime. But it’s coming up more and more in the news and it is becoming a decision point for a lot of operations, particularly offshore. So this has been a real pleasure to learn some of the fundamentals here. And if people that are in invested in wind want to find out more and learn more about the tax law that’s happening right now, particularly United States, how do they pull some of this information. Where can they find you?

David Burton: Yes. So I have a blog. It’s called taxequitynews. com. And you can follow the blog and you can also reach me via LinkedIn David Burton, Norton Rose Fulbright.

Allen Hall: All right, David, thank you so much for being on the program. We would love to have you back. I feel like in six month timeframe, when things get wrapped IRS, we’re going to need to have you back to explain what’s happened in the industry because This is, this has been great. I really appreciate it.

David Burton: It was fun guys. I enjoyed it. Good questions. I’m impressed by your your sophistication about the topic and your podcast sophistication. And it was great.

Joel Saxum: Thanks, David.