Doe anyone know if we have to redistribute the windows in a horizontal band
for Epact modelling, or can addendum a on 90.1 2004 can be used to ignore
this requirement? This is for just HVAC modelling (no envelope changes).
I have on occasion referenced more recent errata, addenda, and versions of standards to justify practices without incident under LEED and COE reviews for energy modeling. I think so long as you are keeping a level playing field between your proposed/baseline and not somehow regressing the model's degree of representation, you ought to be fine.
That said, let me take this into a related tangent: who reviews EPAcT models? Has anybody run into this yet? I find it hard to suggest anything is "safe" considering....
To my understanding, documentation for EPAcT deductions of any sort remain in everyone's filing cabinets until an audit should occur. Such model(s) would therefore only be called into question if the individual/company claiming the tax deductions were audited. In such a case, would the IRS engage an independent, 3rd party staff (i.e. LEED's reviewership) for reviews, or hire/train their own internal branch? Would that review process incorporate a comment/response opportunity to make amends if the reviewer finds something they disagree with, or would the deduction be simply rejected? What implications would that have for those signing off on the EPAcT documentation?
Such questions and grey areas have kept me from pursuing EPAcT modeling with any particular gusto... Has anyone run through a review process, or otherwise know what procedures are or will be in place for such audit scenarios?
from my understanding when the irs reviews epact tax deductions they a)
audit the firm(s) claiming the deduction in full, not just the epact
claim, and b) hire qualified people (i.e. licensed engineers, lighting
people, etc) to review the supporting documentation models, calcs,
certification letter, site installed equipment measurements, etc.
my experience with banding the windows is that it can, depending on your
actual window orientation, give you a bit more percentage saving. it
can of course also take a way a bit of a percent if more of your window
space is moved to orientations where you have less solar heat gain in a
predominantly cooling climate, but living in a predominantly cooling
climate i've gained (and not just epact) and extra percentage point or
so when i have banded the windows. probably works the same way for
heating in a predominantly heating environment but i haven't tried
simulating that case.
from my understanding when the irs reviews epact tax deductions they a)
audit the firm(s) claiming the deduction in full, not just the epact
claim, and b) hire qualified people (i.e. licensed engineers, lighting
people, etc) to review the supporting documentation models, calcs,
certification letter, site installed equipment measurements, etc.
my experience with banding the windows is that it can, depending on your
actual window orientation, give you a bit more percentage saving. it
can of course also take a way a bit of a percent if more of your window
space is moved to orientations where you have less solar heat gain in a
predominantly cooling climate, but living in a predominantly cooling
climate i've gained (and not just epact) and extra percentage point or
so when i have banded the windows. probably works the same way for
heating in a predominantly heating environment but i haven't tried
simulating that case.
Rohini & others:
I have on occasion referenced more recent errata, addenda, and versions of standards to justify practices without incident under LEED and COE reviews for energy modeling. I think so long as you are keeping a level playing field between your proposed/baseline and not somehow regressing the model's degree of representation, you ought to be fine.
That said, let me take this into a related tangent: who reviews EPAcT models? Has anybody run into this yet? I find it hard to suggest anything is "safe" considering....
To my understanding, documentation for EPAcT deductions of any sort remain in everyone's filing cabinets until an audit should occur. Such model(s) would therefore only be called into question if the individual/company claiming the tax deductions were audited. In such a case, would the IRS engage an independent, 3rd party staff (i.e. LEED's reviewership) for reviews, or hire/train their own internal branch? Would that review process incorporate a comment/response opportunity to make amends if the reviewer finds something they disagree with, or would the deduction be simply rejected? What implications would that have for those signing off on the EPAcT documentation?
Such questions and grey areas have kept me from pursuing EPAcT modeling with any particular gusto... Has anyone run through a review process, or otherwise know what procedures are or will be in place for such audit scenarios?
NICK CATON, P.E.
from my understanding when the irs reviews epact tax deductions they a)
audit the firm(s) claiming the deduction in full, not just the epact
claim, and b) hire qualified people (i.e. licensed engineers, lighting
people, etc) to review the supporting documentation models, calcs,
certification letter, site installed equipment measurements, etc.
my experience with banding the windows is that it can, depending on your
actual window orientation, give you a bit more percentage saving. it
can of course also take a way a bit of a percent if more of your window
space is moved to orientations where you have less solar heat gain in a
predominantly cooling climate, but living in a predominantly cooling
climate i've gained (and not just epact) and extra percentage point or
so when i have banded the windows. probably works the same way for
heating in a predominantly heating environment but i haven't tried
simulating that case.
from my understanding when the irs reviews epact tax deductions they a)
audit the firm(s) claiming the deduction in full, not just the epact
claim, and b) hire qualified people (i.e. licensed engineers, lighting
people, etc) to review the supporting documentation models, calcs,
certification letter, site installed equipment measurements, etc.
my experience with banding the windows is that it can, depending on your
actual window orientation, give you a bit more percentage saving. it
can of course also take a way a bit of a percent if more of your window
space is moved to orientations where you have less solar heat gain in a
predominantly cooling climate, but living in a predominantly cooling
climate i've gained (and not just epact) and extra percentage point or
so when i have banded the windows. probably works the same way for
heating in a predominantly heating environment but i haven't tried
simulating that case.