45U phase-out band, 2025-2026 rates
$26.00-$44.75
Gross receipts per MWh over which the credit steps down to zero
Nuclear credits booked by Constellation Energy
$15M
Second quarter of 2026, against $45 million a year earlier
US power transformer market deficit
18%
Wood Mackenzie estimate, with substation transformers at 14%
The first trading day
The Market Bought Credits and Sold Contracted Power
Democrats took the House and the Senate on Nov. 3, and the first trading day in US power stocks priced the result as a clean-energy subsidy story. First Solar rose 8.4% and Enphase Energy 8.8%, while Vistra fell 15.4%, GE Vernova 11.5% and Constellation Energy 9.2% — the names with the largest contracted firm-power books in the market. The filings published that same week pointed the other way: GE Vernova revenue rose 26.8% and Quanta Services 57.4% in their latest quarters. That is a trade on the wrong side of the cash flows, and the reason is that the two credit bills on the table — a Democratic clean-electricity bill from March and the House Republican American Energy Dominance Act from April — both predate the election, and neither has become law.
| Name | Nov. 4, 2026 move | What the move was pricing |
|---|---|---|
| First Solar | +8.4% | Restoration of clean-energy credits |
| Enphase Energy | +8.8% | Same trade, residential solar |
| Sunrun | +6.9% | Same trade, distributed solar |
| NextEra Energy | +4.6% | Tax credits for new renewables |
| Vestas | +2.9% | European renewables read-through |
| Orsted | +4.6% | European offshore wind, then its own reversal |
| EDP Renewables | +2.8% | European renewables read-through |
| Amazon | +6.0% | Hyperscaler that owns its power |
| Microsoft | +6.0% | Hyperscaler that owns its power |
| Alphabet | +4.6% | Hyperscaler that owns its power |
| Applied Digital | -8.8% | Landlord paying market power prices |
| CoreWeave | -9.5% | Landlord paying market power prices |
| Cipher Mining | -21.0% | Landlord paying market power prices |
| GE Vernova | -11.5% | Scrutiny of AI build-out |
| Constellation Energy | -9.2% | Scrutiny of AI build-out |
| Vistra | -15.4% | Scrutiny of AI build-out |
What the sweep changes first
Oversight of AI Power, Not New Subsidies
The fastest thing a Democratic House does is subpoena, not subsidize. Reuters reported that the market's read on Nov. 4 was tougher scrutiny of the AI build-out, more hearings and investigations, and greater responsibility for the power and water costs of data centers. Those costs are being argued where they are actually set: state regulators writing cost-allocation rules for large loads, and FERC, whose December 2025 co-location order for PJM followed a capacity auction that cleared 6,600 MW short of reserve margin. No president who opposes clean-energy subsidies will sign a new credit in January, so the near-term Democratic action is procedural, and procedural is where the cost lands on somebody's income statement.
- Wood Mackenzie's post-election read is that permitting reform, not subsidies, is the likeliest route to faster gas, transmission and wind approvals, and that a Democratic Congress 'does not guarantee legislative success under a Republican White House.'
- The offshore wind compensation file is the first oversight target: roughly $4 billion of 2026 settlement payments to cancel leases, with states already suing over three of the deals.
- Cheaper energy is the quiet offset: Brent fell 8.7% to $94.62 a barrel and WTI 8.3% to $88.12 after the vote, lowering the delivered power cost that scrutiny is aimed at.
The AI buildout will become more expensive, not disappear. Fewer tax incentives and greater responsibility for power and water costs will put pressure on returns, making margins more important for investors.
Offshore wind compensation, 2026
Invenergy lease terminations
$765M
Four federal leases, agreed June 17, 2026
RWE, New York and New Jersey wind farms
$1.22B
Agreed August 2026
TotalEnergies leases
$928M
Federal leases, under congressional inquiry
Total 2026 cancellation settlements
~$4B
Compensation paid to abandon projects
Settlements now in litigation
3 deals
States sued in September 2026
The credit nobody priced
45U Is Switching Off Because Power Prices Are Rising
Section 45U is the most mispriced thing in this file, and it is mispriced in both directions. It was never repealed: the 2025 tax law kept it running through 2032 for reactors placed in service before Aug. 16, 2022, at $3 per MWh rising to $15 per MWh when prevailing wage and apprenticeship rules are met. What is switching it off is the price of power itself. The credit steps down as a plant's annual gross receipts run from $26.00 per MWh to $44.75 per MWh on the 2025 and 2026 rates, so the higher prices that make nuclear equities valuable are the same prices that erase the tax credit. The credit pays most when power is cheap, which is precisely when the nuclear equity is weakest.
Constellation Energy nuclear tax credit revenue has fallen as power prices rose
Nuclear production tax credit revenue recognized by Constellation Energy, in millions of dollars, for the quarterly and first-half periods disclosed in its Form 10-Q for the quarter ended June 30, 2026.
Unit: USD millions
Q2 2025
45
Q2 2026
15
First half 2025
45
First half 2026
25
- The two largest listed nuclear owners booked less credit in their latest reported periods, and the direction is the same in both: Constellation Energy nuclear credit revenue fell to $15 million in Q2 2026 from $45 million, and Vistra transferable nuclear credit revenue fell to $220 million in 2025 from $545 million in 2024.
- What a Democratic Congress could actually do to 45U: widen the phase-out band, extend eligibility to new and advanced reactors, or reopen transferability. None of it is worth much while gross receipts sit inside the phase-out range.
- The reverse is also true and underappreciated: if cheaper gas and slower data-centre demand pull power prices down, 45U returns to full value while merchant margins fall — the credit and the equity move in opposite directions.
Who fills the queue
The AI Power Queue Is Being Filled by Contracts Signed Before the Vote
Every megawatt that will serve AI load between now and 2032 has, for the most part, already been contracted, and none of those contracts depend on who controls Congress. Constellation Energy closed its $21.8 billion purchase of Calpine on Jan. 7, 2026, adding roughly 23 GW of capacity, then signed 920 MW of new long-term nuclear agreements of 15 to 20 years for delivery from 2029 through 2032 and 380 MW of data-centre agreements at Freestone with an exclusive second phase of the same size. Vistra holds a 20-year contract with Amazon for 1,200 MW from Comanche Peak beginning in the fourth quarter of 2027, and 20-year contracts with Meta covering 2,609 MW of PJM nuclear. Signed megawatts are the only AI-power asset that cannot be repriced by a hearing.
| Seller | Counterparty | Size | Terms and timing |
|---|---|---|---|
| Constellation Energy | CyrusOne | 380 MW plus an exclusive second 380 MW phase | Data centre adjacent to Freestone, Texas; first signed in Q1 2026 |
| Constellation Energy | Walmart | 176 MW | Enables a 30 MW capacity expansion at Dresden, Illinois; part of 920 MW of new nuclear agreements running 15 to 20 years from 2029 to 2032 |
| Constellation Energy | Calpine | roughly 23 GW | Acquisition closed Jan. 7, 2026 for about $21.8 billion; serves roughly 62 TWh of load a year |
| Vistra | Amazon | 1,200 MW | 20-year contract from Comanche Peak, delivery from Q4 2027 and fully ramped by 2032 |
| Vistra | Meta | 2,609 MW | 20-year contracts from PJM nuclear; Davis-Besse 908 MW plus an 80 MW uprate, fully delivered by end-2027 |
Upstream
The Constraint Is Transformers, Not Tax Credits
Permitting reform attacks the legal queue; it does not build a transformer. Wood Mackenzie estimates an 18% deficit in power transformers and 14% in substation transformers, more than $10 billion a year of transmission congestion, and high-voltage line completions running at less than half the pace of the previous decade. The equity read-through is already in the order books: GE Vernova ended the third quarter with $46.1 billion of Electrification backlog, growing on switchgear and transformer demand, and Quanta Services grew revenue 57.4% to $12.01 billion while carrying $63.7 billion of backlog. Hardware is the scarce input in this build-out, and it is the one input a tax bill does not produce.
- First Solar: the Section 232 proclamation effective Dec. 4, 2026 sets minimum import prices of $0.38 per watt for modules, $0.22 per watt for cells, $21 per kilogram for polysilicon and $100 per kilogram for ingots and wafers, plus a 15% duty on polysilicon derivatives, and it also collected refunds in the quarter for tariffs the Supreme Court ruled unlawful.
- GE Vernova: Electrification backlog of $46.1 billion against segment revenue of $3.86 billion in the quarter, while Wind backlog of $20.0 billion is down $1.7 billion since year-end on lower North American onshore orders.
- Quanta Services: Electric segment revenue of $9.80 billion and operating income of $1.24 billion, with about $1.22 billion of the revenue increase coming from acquired businesses.
- Daqo New Energy and GCL Technology: Chinese polysilicon and wafer producers sit on the losing side of a tariff-backed US price floor and of the foreign-entity cost-ratio test that would block restored credits from reaching Chinese-controlled projects.
Downstream
Who Pays When Washington Looks at AI Power
The gap the market opened on Nov. 4 was not about renewables. It was about who carries the cost of serving data centres, and the direction of that trade says the hyperscalers won. Amazon rose 6.0%, Microsoft 6.0% and Alphabet 4.6%, while CoreWeave fell 9.5%, Applied Digital 8.8% and Cipher Mining 21%. Buyers that own their power were rewarded; operators that rent it at market prices were sold. Scrutiny of AI power costs is a landlord-versus-tenant problem, and the tenant side is where the equity repricing happens.
- FERC's December 2025 co-location order told PJM to create three transmission service options for co-located data-centre load, and it followed a capacity auction that cleared 6,600 MW short of the reliability requirement.
- In June 2026 FERC issued show-cause orders to all six regional transmission organisations over how large loads interconnect and pay for network upgrades, which is the exact question a Democratic House will ask about data-centre costs.
- Wood Mackenzie expects states to set data-centre cost allocation themselves rather than wait for a federal mandate, spreading the cost question across dozens of regulatory dockets rather than one.
- For CoreWeave the arithmetic is unforgiving: a trailing net loss of $1.93 billion, trailing interest expense of $1.87 billion and capital spending at 2.7 times revenue leave no room for power prices that a hearing can move.
Horizons
What to Watch Between Now and 2029
The next three months are procedural, and procedural is tradable. The Senate was expected to take a cloture vote on Nov. 9, 2026 on the permitting bill that carries the grid reform, and passage needs 60 votes, followed by House passage and a signature. The longer horizon is less about taxes than about what the 2025 law already locked in: wind and solar lose 45Y and 48E for projects placed in service after Dec. 31, 2027, while 45U runs to 2032 and steps out as power prices rise. The event calendar that matters is a permitting vote and a price band, not a tax bill.
| Date | Event | Why it matters |
|---|---|---|
| Nov. 9, 2026 | Senate cloture vote on the Bipartisan American Affordability and Jobs Act | 60 votes needed; sets the pace for permitting reform and grid build-out |
| Dec. 4, 2026 | Section 232 minimum import prices take effect | Polysilicon $21/kg, ingots and wafers $100/kg, cells $0.22/W, modules $0.38/W |
| Q4 2026 | Fourth-quarter power prices set the 2027 curve | Decides whether 45U keeps fading or starts paying again |
| January 2027 | New Congress returns and oversight letters begin | First substantive questions on AI power costs and nuclear |
| 2027 | Wind and solar credit termination for projects placed in service after Dec. 31, 2027 | Makes a restoration bill expensive and therefore contested |
| 2032 | 45U credit expires | The nuclear subsidy cliff unless a later Congress extends it |
Power, grid and AI-load names touched by the sweep
- 920 MW of new long-term nuclear agreements for 2029-2032, plus 380 MW of CyrusOne data-centre contracts, make contracted volume rather than credits the growth driver.
- Nuclear tax credit revenue fell to $15 million in the second quarter of 2026 from $45 million a year earlier, so 45U is not the earnings engine.
- Calpine added roughly 23 GW for $21.8 billion and the Walmart agreement enables a 30 MW uprate at Dresden.
- Horizon: 2027-2030 delivery of contracted megawatts is the test; a restored credit changes nothing for a plant already running.
- 1,200 MW contracted with Amazon and 2,609 MW with Meta run to 2032 and 2034 on schedules already fixed.
- Third-quarter revenue rose 27.7% to $6.35 billion while the shares fell 15.4% on Nov. 4.
- Up to $1 billion committed to the Helix fund puts Vistra on the developer side of the build-out it sells power into.
- Horizon: nuclear credit revenue of $220 million in 2025 against $545 million in 2024 shows the credit shrinking as contracted power grows.
- Electrification backlog of $46.1 billion, growing on switchgear and transformer demand, prices the 18% transformer deficit directly.
- Third-quarter revenue rose 26.8% to $12.64 billion while the shares fell 11.5% on Nov. 4.
- Wind backlog of $20.0 billion is down $1.7 billion since year-end as North American onshore orders fell.
- Horizon: 2027-2029 permitting reform feeds the equipment queue faster than the wind queue.
- Revenue rose 57.4% to $12.01 billion in the third quarter with $63.7 billion of backlog, over half of it in the Electric segment.
- Transmission construction is paid for by interconnection queues, which no tax credit fixes.
- About $1.22 billion of the Electric revenue increase came from acquisitions, so backlog conversion matters more than the growth rate.
- Horizon: 2027-2028 backlog conversion is the test; permitting reform lengthens the build cycle Quanta sells into.
- Section 232 minimum import prices of $0.38 per watt for modules and $21 per kilogram for polysilicon take effect Dec. 4, 2026, and they, not Congress, set price.
- A 44.0 GW backlog worth $13.5 billion through 2030 is largely contracted at tariff-protected pricing.
- Third-quarter net sales fell 22.8% to $1.23 billion even as gross margin held at 57.9%.
- Horizon: the December price floors and the 2027 credit votes decide whether US plants that clear the foreign-entity screen get restored credits.
- A trailing net loss of $1.93 billion and $1.87 billion of trailing interest expense leave no room for power and water costs Washington now scrutinizes.
- The shares fell 9.5% on Nov. 4 while Amazon, Microsoft and Alphabet rose, so the market is repricing who carries AI power risk.
- Net debt of 11.5 times trailing EBITDA and capital spending at 2.7 times revenue put every price rise on the same line.
- Horizon: state network-upgrade cost allocation and FERC's large-load rules are the catalysts; a restored credit does nothing for a power buyer.
- Gross profit was negative $60.7 million on $194.7 million of third-quarter revenue, so the chain is selling below cost.
- The foreign-entity cost-ratio test would exclude Chinese-controlled projects from a restored 45Y and 48E, making the 2027 credit votes asymmetric against it.
- Section 232 minimum import prices of $21 per kilogram for polysilicon take effect Dec. 4, 2026, the one lever that lifts US clearing prices.
- Watch Dec. 4, 2026 price floors and the 2027 tax debate; neither is a demand catalyst.
- GCL Technology makes granular polysilicon, silane gas and wafers, so the $21 per kilogram US floor is a direct price reference for its output.
- The 15% duty on polysilicon derivatives and the foreign-entity cost-ratio test stop that floor from turning into restored US credits.
- Its perovskite module and wafer lines face the $0.38 per watt US module floor that protects domestic manufacturers.
- Horizon: 2027 credit votes in Washington decide access to US demand, not the December price floors.
