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power using the transmission line systems before the installation
of the components at issue. When a unit of property has been
placed in service and is available to perform its intended
function, component parts added to the unit after it has been
placed in service constitute separate pieces of property. See
Armstrong World Indus., Inc. v. Commissioner, supra at 434-435.
The fact that the transmission line systems received power before
petitioner installed these components indicates that the Jensen-
Midway-Turnpike and the Andytown-Lauderdale transmission lines
functioned properly without the additional components at issue.
Instead, the components at issue enhanced the reliability of the
Jensen-Midway-Turnpike and the Andytown-Lauderdale transmission
lines, helping petitioner meet the growing demand for power.122
122 Mr. Sanders testified:
The dispatch of the resources to serve the load
changes over time, and the facilities that you would
place in service, say, initially to receive the power
may not be all that’s required to receive the power
forever or through the duration of whatever period of
time you plan on buying power. As time marches on, the
dynamics of the resources serving the load change.
Part of system planning is to continually review
the plans that we have for expansion and decide whether
or not it’s prudent to add a particular facility at a
particular point in time or not. We may think we need
A, B, C, D pieces, but we only need A and B to begin
with, and part of planning is to continually reevaluate
that plan and to decide whether or not you really need
C and D * * *
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