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the substation. Finally, construction would begin, typically in
three phases: Site prep work (clearing trees and vegetation on
the property); substation construction; and installation and
testing of equipment. FPL individually named each distribution
and transmission substation, normally on the basis of geography.
A plot plan was essentially FPL’s overall layout of the
substation on the piece of property. The plot plan graphically
illustrated the general orientation of the high voltage bus work,
location and number of transformers, location of the relay vault,
and all low voltage distribution substation equipment. FPL
created the plot plan when it prepared the substation’s first
budget item because the budget was based upon the plot plan.
FPL claims an ITC for equipment installed at numerous
substations, including transformers and feeders. In the interest
of brevity and ease of explanation, a table has been prepared to
illustrate FPL’s claims that is attached as appendix A.
With respect to the distribution and transmission
substations, petitioner incurred capitalized costs (tax basis) of
$3,264,386, $8,091,517, and $4,413,670 for equipment placed in
service in 1988, 1989, and 1990 taxable years, respectively.
K. Regional Planning
FPL had a distribution planning group that planned and
provided for an orderly, cost effective expansion of FPL’s
electrical distribution system over the long term. The
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