Walker Blue partnered with Warren Woods Public Schools to certify and maximize the Investment Tax Credit (ITC) for a solar energy project at Warren Woods Tower High School in Warren, Michigan.
The 300 kW AC roof-mounted photovoltaic (PV) system was installed in conjunction with a roof replacement project necessary to support the solar array. Of the total project cost of $2,310,365, Walker Blue identified $1,839,592 as ITC-eligible basis. The resulting 40% total ITC generated a tax credit value of $735,836, available to the district through Elective Pay (Direct Pay).
Warren Woods Tower High School serves grades 9–12 and functions as a central academic and community hub. With multiple classroom wings, science labs, athletic facilities, and offices, the campus carries substantial and consistent electrical demand.
The new PV system integrates with existing infrastructure to offset a significant portion of annual electricity consumption while visibly reinforcing the district’s commitment to sustainability and STEM education.
Overview
Type of Project: 300 kW AC roof-mounted photovoltaic (PV) system
Construction Start: December 29, 2023
Placed in Service: December 27, 2024
Scope of Review
Walker Blue conducted a comprehensive ITC eligibility analysis under IRC §48, including a detailed review of:
- Design drawings and engineering documentation
- Executed contracts and vendor quotes
- Pay applications and cost breakdown schedules
- Domestic content sourcing documentation
- Prevailing Wage and Apprenticeship (PWA) compliance analysis
Overview of Cost Basis
Total Project Cost: $2,310,365
ITC-Eligible Cost Basis: $1,839,592
Final ITC Rate: 40%
Total ITC Value: $735,836
Base ITC Rate:
6% for qualifying energy property under Section 48 with the 5X multiplier for meeting PWA requirements for a total of 30%.
Prevailing Wage & Apprenticeship (PWA):
The system’s 300 kW AC capacity falls below the 1 MW threshold under IRC §48(a)(10)(D)(i), automatically satisfying PWA requirements and preserving eligibility for the full 30% base rate.
Domestic Content Adder:
Although the project did not qualify under the simplified safe harbor, Walker Blue performed a full cost-trace analysis confirming domestic manufactured product content exceeding 40%, consistent with the applicable threshold for projects beginning construction in 2023, qualifying for 10% bonus credit.
Energy Community Adder:
Not applicable. The project site is not located within a qualifying Energy Community under IRS Notice 2023-29.
Eligible Cost Methodology
Walker Blue applied IRS-aligned allocation principles to determine the defensible ITC basis.
Roofing Cost Treatment
Because the solar installation required structural roofing work, an area-based proration methodology was applied to determine the portion of roofing costs integral to the PV system.
- PV-related roof area to total roof area ratio: 60.79%
- That percentage was applied to total roofing expenditures to determine eligible costs.
This approach ensured only roofing costs directly necessary for installation and long-term operation of the solar energy property were included.
Tax Credit Summary
Applicable ITC Rate: 40 percent (30 percent base + 10 percent Domestic Content bonus)
Eligible Cost Basis: $1,839,592
Total ITC Value: $735,836
Through a detailed ITC eligibility, cost allocation, and Domestic Content analysis, Walker Blue confirmed that the Warren Woods Tower High School solar project qualifies for a 40 percent federal Investment Tax Credit, resulting in a total tax credit value of $735,836. The engagement established a defensible ITC basis, validated compliance with prevailing statutory and IRS guidance, and ensured the district was positioned to fully capture available federal incentives while mitigating audit risk.
