Table of Contents
1. The False Sense of Security
Most solar developers today believe risk is largely “managed” once key compliance milestones are met. FEOC considerations are addressed. Safe Harbor equipment is secured. Procurement contracts are in place.
At that point, the project often feels de-risked. But that assumption is increasingly proving incorrect.
In the 2026 market, compliance does not guarantee execution success. It only confirms that a project is eligible to proceed. We are seeing a growing number of solar projects that are technically compliant on paper but still fail to reach commercial operation.
The issue is no longer policy uncertainty. It is execution breakdown between procurement, logistics, and construction. Compliance is no longer the finish line. It is only the entry point.
2. Compliance ≠ Execution Readiness
Securing equipment and meeting Safe Harbor requirements represents only one part of project delivery.
The more critical challenge is maintaining continuity of construction under current IRS guidance and ensuring that procurement activity is fully aligned with physical execution.
How equipment is allocated, tracked, and integrated into construction sequencing determines whether a project maintains eligibility and financial integrity.
In practice, procurement is still often treated as a transactional milestone. Once the purchase order is signed, teams shift focus elsewhere. This creates a structural gap between procurement planning and field execution.
Between warehouse staging and installation in the field, there are multiple failure points that can impact timelines, increase costs, and in some cases, jeopardize tax credit eligibility.
3. Where Projects Break in Execution
A. Documentation Gaps and the Audit Trail
Safe Harbor is not only about securing equipment. It is about establishing a defensible, traceable link between each unit of equipment and a specific project.
Incomplete serial tracking, inconsistent allocation records, or missing documentation are among the most common reasons projects face challenges during tax equity review or audit processes.
If equipment cannot be clearly tied to a defined project scope, compliance exposure increases significantly.
B. EPC and Procurement Misalignment
A recurring issue in project execution is the disconnect between procurement timing and EPC construction sequencing.
When equipment purchasing decisions are made without real-time coordination with field readiness, logistical friction is created.
This often results in:
- Equipment arriving before site readiness
- Increased storage requirements and handling risks
- Demurrage costs and scheduling inefficiencies
- Disruption to planned construction sequencing
C. The Allocation Pivot Risk
In high-pressure scenarios, developers may reassign Safe Harbor equipment from one project to another to address delays or shortages.
Without a robust tracking and documentation system, this “operational adjustment” can quickly become a compliance issue.
Misaligned allocation records can create inconsistencies that affect both projects, potentially impacting ITC eligibility and audit defensibility.
4. The Real Issue: Fragmented Execution
Most solar projects do not fail due to regulatory uncertainty.
They fail because procurement, logistics, and construction operate in silos rather than as a coordinated execution system.
Compliance frameworks assume alignment across these functions. In practice, that alignment is often missing.
The result is a widening gap between intent and execution.
5. The ESAS Perspective: The Execution Layer
At Energy Solutions and Supplies (ESAS), we operate in the space between procurement strategy and physical project execution.
We are not solely a distributor. We function as an execution layer that helps align procurement decisions with field reality.
Our role is to help reduce fragmentation by supporting:
- Real-time allocation visibility to ensure project-level traceability
- Coordination between procurement timelines and EPC construction sequencing
- Logistics planning aligned with site readiness and delivery constraints
- Chain-of-custody discipline to support documentation and compliance requirements
The objective is not only equipment delivery, but execution continuity from procurement through installation.
Conclusion
Most solar projects do not fail because of shifts in federal policy. They fail in the operational gap between equipment delivery and installation, the final 50 yards between logistics and construction.
That gap represents one of the highest concentrations of execution risk in the entire project lifecycle.
Compliance may qualify a project. Execution determines whether it succeeds.
Disclaimer
This newsletter is intended for informational purposes only and does not constitute legal, tax, or financial advice. Safe Harbor eligibility, Investment Tax Credit qualification, and related compliance requirements are subject to interpretation by qualified professionals and may vary based on project-specific conditions and evolving regulatory guidance. Readers should consult their legal and tax advisors for advice specific to their projects
Let’s Discuss
Are lenders or customers already asking your team for FEOC documentation on your projects?
We’d be interested to hear how procurement and compliance expectations are evolving in your market.
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Energy Solutions and Supplies LLC
Phone: +1 480-478-1616
Website: www.energysolutions-solar.com
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