; (1) Applicable percentage The term applicable percentage means— (A) 50 percent in the case of a qualified zero-emission electricity generating unit that begins to generate electricity before December 31, 2025, (B) 40 percent in the case of a qualified zero-emission electricity generating unit that begins to generate electricity before December 31, 2030, and (C) 30 percent in the case of a qualified zero-emission electricity generating unit that begins to generate electricity before December 31, 2037. (2) Generating unit The term generating unit has the meaning given such term in section 201 of the Clean Energy Innovation and Deployment Act of 2020 . (3) Qualified zero-emission electricity generating unit The term qualified zero-emission electricity generating unit means a generating unit— (A) that is placed into service after the date of enactment of this section, and (B) the operation of which does not result in the release of carbon dioxide into the atmosphere. (4) Qualified zero-emission electricity taxpayer The term qualified zero-emission electricity taxpayer means, for a taxable year, a taxpayer who— (A) does not own a generating unit that emits carbon dioxide at any point during such taxable year, and (B) for such taxable year, owns non-emitting electricity generating units with a generating capacity that is equal to or greater than the annual average generating capacity of generating units owned by such taxpayer during the 5-year period ending on the date of the enactment of this section. (c) Transferability (1) In general If the qualified zero-emission electricity taxpayer elects to transfer all (or any portion specified in the election) of the credit determined under this section for any taxable year with respect to any qualified facility to an eligible project partner for a specified period, then, the eligible project partner specified in such election (and not the taxpayer) shall be treated for purposes of this title with respect to such credit (or such portion thereof) as the person producing and