An Indiana company is in the business of developing and manufacturing electricity using a new technology that is “cleaner” than methods traditionally used with emissions levels that fall below both current and anticipated future environmental standards. The issue at hand is whether the equipment and the other consumables used in the electric generating facility are exempt under either the manufacturing exemption or the pollution control exemption. In a Revenue Ruling the Department determined that the equipment and consumables were exempt under the manufacturing exemption because they were used in the direct production of electricity. The environmental exemption did not hold because the equipment was not purchased in order to comply with any environmental standard or regulation. (Revenue Ruling No. 2004-01 ST, Indiana Department of Revenue, June 28, 2004)