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integrated pieces of property, petitioner argues that the
components at issue satisfy the requirements of TRA section
203(b)(1)(B). Respondent argues that these component parts
constitute separate pieces of property, which fail to satisfy the
requirements of TRA section 203(b)(1)(B).
We find that petitioner misinterprets the single property
rule to allow components to constitute a single piece of property
when “all of the component sections and related substations were
planned and designed to serve a specific, integrated function”.
As we discussed in the analysis of the SJRPP “wrap up” work and
“enhancements and deficiencies” work, Haw. Indep. Refinery, Inc.
and Consumers Power Co. hold that components make up a single
unit of property when each component is necessary for the unit to
operate as intended at the time that the unit is placed in
service. Petitioner’s components differ from those in Haw.
Indep. Refinery, Inc. and Consumers Power Co. because
petitioner’s substations performed their intended function when
they were placed in service several years before the addition of
the components at issue.
Because the relevant facts for each component at issue are
very similar, we shall not address each item individually.119 We
shall use the Alva substation as a representative example. The
119 See appendix A for a list of the distribution and
transmission substation components for which petitioner seeks an
ITC.
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