Bridgestone Associates conducted a Sales and Use Tax Exemption Study for Carson Helicopters, Inc., a manufacturer of helicopter blades and components, and a re‐manufacturer of commercial helicopters in Perkasie, Pennsylvania. Under the Commonwealth of Pennsylvania Code, the energy used directly in the process of manufacturing, or in this case remanufacturing,
in facilities within the Commonwealth is exempt from Sales and Use Taxes. However, the remainder of the energy used within the same facility for non‐manufacturing purposes is subject to these taxes and, as a result, the manufacturing and nonmanufacturing uses must be distinguished for tax
Bridgestone conducted a detailed study of all electrical equipment used in the manufacturing and remanufacturing processes, developing a complete list
of equipment and its nameplate data. With input from facility staff on operating hours, frequency of operation, etc. for each piece of equipment, Bridgestone calculated the annual energy use for each piece of equipment. Bridgestone then calculated the total annual energy use for manufacturing and remanufacturing. This was then compared to the total facility use in order to calculate the percentage that should be exempt from sales and use taxes.