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authorized to $4.7 million for the construction of the simulator
training facility at Turkey Point.44
With respect to the construction of the simulator training
buildings, petitioner incurred capitalized costs (tax basis) of
$1,486,050, $1,458,213, and $345,914 for equipment placed in
service in the 1988, 1989, and 1990 taxable years, respectively.
E. Load Management System
A load management system (LMS) is a group of components that
control appliances in customers’ homes to reduce peak demand for
electricity. Peak demand is the time during the day with the
highest demand for electricity. In reducing the demand during
peak times, load management reduces FPL’s need to construct
additional facilities to provide electricity. Load management
reduces peak demand by remotely turning on and off certain
appliances in customers’ homes. Customers voluntarily
participate in the LMS, and FPL gives its customers rebates in
exchange for their participation. FPL claims ITCs for the LMS in
the 1988, 1989, and 1990 taxable years.
The three major components of the LMS are the central
computer, the substation control equipment, and the transponders
located at customers’ homes. Telephone and power lines connect
44 Mr. DePlonty testified that physical construction of the
St. Lucie plant training facility did not start until after April
1986. However, Mr. DePlonty testified that development of the
simulator, a training aid, began before the construction of the
building that housed the simulator.
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