Elevation of unguarded live parts Art. 110.34

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boat64

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Pennsylvania
Table 110.34(E) requires 9'6" elevation of unguarded live parts above working space: the question is; On an incoming 34 KV substation type transformer, with top bushing, feeding from a primary metering structure, with open wire, required to be a minimum of 9'6" to the top of the bushing?
Is the area below the top of the bushing considered "work space" given that the body of the transformer occupies this space.
 
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