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in service in the 1988, 1989, and 1990 taxable years,
respectively.
J. Distribution and Transmission Substations
A distribution substation transforms transmission voltage of
electricity from high voltage/lower current to low voltage/higher
current; i.e., to “distribution voltage”. The distribution
voltage is distributed through feeder wire (either overhead or
underground), then through either aerial or pad-mounted
transformers, and then to utility customers (residential or
commercial). A transmission substation either consolidates
transmission lines or transforms voltage from one voltage to
another. FPL used similar procedures for designing and
constructing distribution substations to those it used for
transmission substations. Typically, FPL builds a distribution
substation on approximately 5 acres of property, with
approximately 1 acre in the middle of the property developed for
the substation. FPL claims ITCs for the distribution and
transmission substation components in the 1988, 1989, and 1990
taxable years.
The most important components of a distribution substation
are the “power transformers” (transformers) because this
equipment transforms the voltage from transmission voltage to
distribution voltage. Also, the transformers are significantly
more expensive than the other items in the substation. A
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