[bldg-sim] Tax Credit Question

[Matthew Dubrovich]

A few things I've noticed in the IRS notice (
http://www.irs.gov/irb/2006-26_IRB/ar11.html ) ...

 

Section 3 - Method of Computation notes that "The energy performance of
the Reference Building shall be determined by following the methods for
baseline building performance in the PRM in Appendix G of Standard
90.1-2004"  (not 2001).  However, the Reference Building should meet the
minimum requirements of Standard 90.1-2001 plus some requirements of
Title 24.  In part 2 of section 3, the IRS goes on to say that the 50%
savings should be calculated using only the Interior Lighting, Heating,
Cooling, Ventilation, and Hot Water components of the models.  There is
no mention of process loads which, according to 90.1-2004 App. G, should
be included in the savings calculation.  It appears that the calculation
and model should be based on a hybrid of 90.1-2001, 2004, Title 24, and
some IRS-specific requirements.  

 

Has anyone else come to the same conclusion based on what information we
have on this deduction?

 

Also, it would be great to hear of any experiences with the deduction.  

 

Thanks,

 

Matt Dubrovich

 

EMC Engineers, Inc.

www.emcengineers.com <http://www.emcengineers.com/> 

Making buildings work.  Better.

Direct: (303) 974-1217

(303) 974-1200

(303) 974-1239 (fax)

 

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________________________________

From: bldg-sim at gard.com [mailto:bldg-sim at gard.com] On Behalf Of Lee
DeBaillie
Sent: Monday, February 05, 2007 12:44 PM
To: bldg-sim at gard.com
Subject: [bldg-sim] Tax Credit Question

 

Justin,

 

I don't believe the guideline has been issued.  It appears to be the
last missing piece of information necessary to complete an actual
certification letter under the interim guidelines issued Nov06.  From
what I can piece together, because of this, you can do the energy
analysis but you can't actually apply for the tax deduction without a
certification letter, which requires among other things a building
inspection conforming to the missing guidelines.  Does anyone know of a
successfully completed project?

 

NEMA has protested this requirement to the US Treasury Department last
summer - see below.

 

Lee

+++++++++++++++++++++++++++++

In a letter to the U.S. Treasury Department commenting on the IRS
guidelines, NEMA has taken the position: "The requirement of the Notice
that this field inspection be performed in accordance with NREL
procedures is unnecessary and inappropriate for the interim rule, which
is independent of energy-saving targets. Qualified individuals already
exist that can inspect an installation to assure that a lighting design
that is consistent with the prescriptive requirements of the interim
rule has been installed in the building. There is no need for new NREL
requirements."

As of August 21, Treasury has not responded to these comments in an
actionable manner.

http://www.aboutlightingcontrols.org/education/papers/taxdeduction2.shtm
l
<http://www.aboutlightingcontrols.org/education/papers/taxdeduction2.sht
ml>  

++++++++++++++++++++++++++++++


>>> "Justin Aruck" <jaruck at emoenergy.com> 2/5/2007 12:43 PM >>>

________________________________

From: Justin Aruck [mailto:jaruck at emoenergy.com]
Sent: Monday, February 05, 2007 1:11:19 PM
To: bldg-sim at gard.com
Subject: [bldg-sim] Tax Credit Question

 

Does anybody know the status of the NREL "Energy Savings Modeling and
Inspection Guidelines for Commercial Building Federal Tax Deductions"
that is supposed to be used to certify buildings for the commercial
building tax deduction?  It seems to be referenced all over the place,
but I can't find it.  Any help would be very much appreciated.

 

Thank You,

 

Justin Aruck, LEED-AP

Project Manager

EMO Energy Solutions, LLC

2733 Hartland Road

Falls Church, VA 22043

Phone: 703-205-0445  x122

Fax: 703-205-0449

 

 
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