- 166 - 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.Page: Previous 156 157 158 159 160 161 162 163 164 165 166 167 168 169 170 171 172 173 174 175 Next
Last modified: May 25, 2011