Rick,
Slow down a bit, you got some facts wrong. 

The IRS did NOT grant the project tax-exemption. That is what they wanted you to think, which is why AGDC won't share their PLR request. What the IRS said is that the company is exempt from taxes. That is a HUGE difference, and nobody in their right mind ever thought otherwise (they are a public corporation owned by the state, of course they don't pay taxes or AIDEA, APFC and AHFC would be paying them).

As far as their ability to issue tax-exempt debt, that may be true in theory. However, like most theories, the details get in the way when you try to apply them to reality. There are technical tax issues that I won't get into since debt issued for this project would never get that far. Lenders are very peculiar in that they want to get repaid all of the money they lend. To ensure this, they want some type of collateral. The SOA has only the PF to put up for collateral (i.e. no binding contracts), and that isn't going to happen. The end