110.31 - 10 Feet Around Substation?

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We are designing a unit substation installation that is to be surrounded by a chain link fence. The substation is taking in 12.47 KV and stepping it down to 480V for distribution.

Does 110.31 require 10 feet of space ALL AROUND the substation? Meaning I would need 10 feet between the substation and the fence in all directions (North/South/West/East). Seems like a lot of space required.

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If this is totally enclosed equipment the fencing and it's spacing requirements are optional, as there are no exposed parts.

If there is some open air/exposed equipment or conductors is any of it subject to POCO rules?
 
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