Burning Torch

Subject: Public Testimony; HB 550 – Just how does Hawaii get to a clean energy economy by 2045?

Renewable Portfolio Standard; Gas; Electricity; Study; Appropriation
Description:Requires the Public Utilities Commission to study the feasibility of implementing renewable portfolio standards to encourage the use of renewable energy by gas utility companies. Amends the renewable portfolio standard interim goals for 2030 and 2040 to accelerate the adoption of renewable energy. Appropriates funds. (HB550 HD1)

Subject: Public Testimony; HB 550

Submission Date: Thursday, February 21, 2019

To whom it may concern,

It is easy to understand and support the opening premise of this bill (HB550), until the reader reaches SECTION 2, Chapter 269, and the details of how HB550 will amend the current law governing the state’s Renewable Portfolio Standards.

First, the entire premise of the bill is flawed, for it is impossible for Hawaii Gas in its mission to sell fossil fuels to be an effective partner in Hawaii’s RPS goals and transition to a clean energy economy, designed to eliminate fossil fuels from the state’s energy mix.

Second, Section 2 Chapter 269 (3) seeks to use taxpayer and ratepayer funding through so-called “public utilities special fund” and to apply monies toward an ill-conceived objective that somehow Hawaii’s Gas utility will be somehow shoehorned into the current RPS compliance goals, while continuing to sell and distribute natural gas and other fossil fuels products in Hawaii.

Third, Section 2 Chapter 269 (3)(C)(i) calls for the identification of renewable alternatives, such as the procurement and importation of biogas. This mandate fails on several fronts, specifically, the importation of biogas, which runs contrary to the state’s RPS transition to locally produced clean energy independence, or that biogas qualifies as a clean energy (zero emissions) energy substitute.

Fourth, Section 2 Chapter 269 (3)(D) Unregulated gas sales and what requirements are needed for the transition of gas that is unregulated to a renewable energy source   Once again, and throughout the false of premise of this HB 550, is the idea that a fossil fuel with the greenhouse gas emissions half that of burning the dirtiest fuel available today, coal, can somehow be considered a clean or renewable energy fuel source, regardless of its application within Hawaii’s energy mix.

Fifth, HB 550 goes onto state… “The legislature is concerned that requiring electric utilities but not gas utilities to increase their reliance on renewable energy creates an unfair playing field that may unintentionally harm consumers by promoting suboptimal long-lived investments in fossil fuels through gas-fired distributed electrical generation.”

HB550 is designed to address one thing; above all, that is the preservation of Hawaii Gas and its fossil fueled business model.

A much more effective means of addressing the state’s current 2045 RPS goals, and needed reform that addresses all energy stakeholders: First, vote NO on HB 550, and then propose and put forward for full legislative consideration a statewide carbon tax which rewards “zero emissions” energy production and its public consumption.

Burning Torch

Will Rolston Pic

Lālāmilo Wind Farm – A Big Island Clean Energy Success Story in Jeopardy

Lālāmilo Wind Farm 1 Lālāmilo Wind Farm Map 2

“This (Lālāmilo Wind Farm) is arguably the first time in Hawai’i, and perhaps the nation, that a local government has developed such a wind-powered, water-pumping facility capable of significant greenhouse gas reductions at no-cost to the taxpayer”  – United States Conference of Mayors’ Climate Protection Awards – Honorable Mention


Lālāmilo is a wind and water system that works with complete synchronicity delivering customer savings while improving the environment for our island.   The Lālāmilo and DWS wind-water system is responsible for moving water to household customers, ranches and the large resorts and provides power to eight (8) deep wells managed by Hawaii Island’s Department of Water Supply, and that represent approximately 25% of the $20 million the department’s energy bill essential to its water system.

The history of the Lālāmilo Wind Farm goes back to the mid-1980s, where the original Lālāmilo Wind Farm developers knew enough about the wind resource in Hawai`i and the Lālāmilo water site that they proposed and eventually developed a wind farm using 1980 technology Jacobs Wind turbines that would both power water pumping operations and when available, provide excess energy to the local electric utility, Hawai`i Electric Light (HELCO).

That original wind farm worked well for a period of time and HELCO’s holding company Hawaiian Electric Industries purchased the wind farm around the year 2000 and included it in HELCO’s renewable energy percentages numbers for the next decade.

The consistent and sometimes destructive wind at the Lālāmilo site eventually destroyed many of the 120 plywood wind turbines and twisted the metal tower structures supporting those turbines into steel pretzels. Combined with a lack of maintenance and spare parts, the wind farm degraded to a point where it was not producing significant energy.

Just before the wind farm was set to be decommissioned in 2010, HELCO proposed re-powering the wind farm with approximately $10 million using more modern and efficient renewable energy technologies, but the parent company was not interested in a wind farm that would be third in line with two other ones already operational and in priority order of dispatch, namely the Hawi (Upolu Point) and Tawhiri (South Point) wind farms.

When I invited National Renewable Energy Laboratory (NREL), a Department of Energy Lab focused solely on Renewable Energy, to the Lālāmilo site in 2009 they were astounded that a relic of early renewable energy systems remained. The wind was blowing steady, as two NREL engineers walked around the historical site in awe.

With stormy skies as the backdrop and only a few turbines spinning with twisted metal towers and plywood blade shards lying about, they took many dramatic pictures determined to bring back home to enchant their fellow engineers. More remarkable to the experienced engineers was that the largest island water pumping system sat under this world-class wind resource.

The Lālāmilo water system responsible for moving water to household customers, ranches and the large resorts comprise eight (8) deep wells that consume approximately 25% of the $20 million Water Department energy bill.  NREL engineers then reported back headquarters at Golden, Colorado, easily convincing their colleagues and superiors of the potential to re-power this unique site.

With NREL’s support, I worked diligently with the help of the Water Department’s energy analyst to form an alliance that could successfully lobby to receive Federal grant money from the 2008 Hawaii Clean Energy Initiative for assistance with many technical aspects of the project.

Most of these Federal dollars were used for the rigorous analysis of the wind’s capability to pump water from the eight (8) deep water wells at the Lalalmilo site.

We were also able to get additional Federal dollars to employ a top law firm in Hawai`i to write the legally-binding and highly-technical document that would become the Power Purchase Agreement (PPA). With some insightful modifications from County’s Corporation Counsel, the PPA spelled out the legal terms for the supply and purchase of the wind power.

With the help of NREL visits, we presented to the Water Department – Water Board several times during the period 2010 to 2012; educating them on the wind farm benefits and gaining their full support to go forward with this project. During those presentations, some of the Water Board were shocked that such a well-known and high-caliber Department of Energy – National Lab was interested in them and the Lālāmilo water system.

This was also at a time when HELCO rates had recently been at all-time-highs due to high oil prices and there was tremendous pressure on the Water Department to find solutions to alleviate ever-increasing customer power charges.

The wind farm project all made sense to everyone and the Water Department with the support of the Water Board decided that the re-powering of Lālāmilo was a priority solution to the ultimate goal of saving water ratepayers $1 million per year.

After releasing a Request for Qualifications in 2012, seven (7) bidders sent in their responses to be considered as bidders for the project. As the three-person Evaluation Committee reviewed those qualifications, we whittled those down to three (3) credible developers. The final steps of the process included an initial proposal to the RFP, an in-person (or team) interview along with a Best and Final Offer.

When the interviews were done and final offers reviewed, the unanimous winner was Lālāmilo Wind Company (LWC). LWC had proven they had the experience with their superlative track-record at the Hawi Wind Farm and also that they could provide just what the Water Department needed, namely maximum cost-effective renewable energy that could save their water customers money.

The Evaluation Committee presented their recommendation to the Water Board on April 23, 2013 and the Water Board went into Executive Session for 12 minutes and came out to declare LWC the unanimous winner. To say the least, I was overjoyed that here was a project that would set the new standard for the Water Department and the State of Hawai`i. I had gotten a chance to work with some of the best engineers on the island in the Water Department and we had done the right-thing by selecting the best developer possible.

The PPA was signed in October 2013 and LWC got to work financing and building the wind farm they had agreed to according to the Water Department specifications. Some minor adjustments to the PPA were made that included providing for a Habitat Conservation Permit and Incidental Take Permit, but things were going rather smoothly.

In September 2015, we held a blessing on the Lālāmilo site and as show of approval, the Lālāmilo winds blew gently right on queue and then increased in strength. Public press releases and public speeches rolled from the Water Department announcing the coming of a new wind farm capable of saving the County water ratepayers $1 million per year.

By September 2016, only one year after we broke ground, LWC fulfilled their commitment by producing a modern wind farm capable of handling the extreme wind regime at Lālāmilo and converting that energy in useful electricity for the entire Lālāmilo water system.

For one year starting from September 2016, the wind farm operated in the daytime only as we waited on the results from the Federal approvals and then in September 2017 it went fully-operational. With the new Saddle Road extension complete, most people started to get a regular glimpse of the elegant wind farm as they drive west.

Most folks can see the wind farm as they drive past Waikoloa on the lower road and many see it as the use the upper road to Waimea. As a true testament to LWC’s skill in development and community outreach, there have been no complaints or protests as you see more and more both in Hawai`i and around the world. Recently, in a great wind month like August 2018 that has had consistent wind, you can see all turbines whirring purposefully to pump water.

Unbeknownst to many on this island or the State of Hawai`i, the world was watching our little Big Island as the uniqueness of the Lālāmilo Wind Farm has been in the national spotlight at last year’s United States Conference of Mayors’ Climate Protection Awards.

In the Climate Protection Award category for Large City – Honorable Mention it was written “This is arguably the first time in Hawai’i, and perhaps the nation, that a local government has developed such a wind-powered, water-pumping facility capable of significant greenhouse gas reductions at no-cost to the taxpayer.”

DWS Dispute

Although Lālāmilo Wind Farm is a very significant accomplishment recognized by over 1400 diverse governments including some of the most sophisticated counties & cities, unfortunately, today there is a contractual dispute which prohibits the Lālāmilo Wind Farm from doing what it was designed do.

The main issue at stake is ‘what is the minimum wind energy contracted by the Water Department’. Or from wind farm owner’s point of view, ‘what is the minimum energy that was signed in the contract and relied on to make the project financially viable?’ The Water Department – Water Board has turned the matter over to their lawyers at the County Corporation Counsel.

While this dispute seems to me to be easily resolved, as a former County Energy Coordinator, I have the highest respect for everyone at the Water Department that comprise some of the best engineers I have known since my days working as with top engineers at places like Westinghouse and Siemens.  There is every reason for these high-caliber engineers to be proud of a Nationally-recognized wind farm that is part of the most-sophisticated wind-water system in the United States. That means it will take LWC and Water Department working even more collaboratively on continuous quality improvement to match the abundant wind power to the deep water pumps needs and reservoir levels this site.

As an independent consultant, I have made myself available to the Water Department and Water Board in investigating this minimum contact energy issue which was the basis for initiating the project and designing the RFP and PPA from 2009 to 2013.

Today, I am especially encouraged by the persistent efforts of the Water Department as they have recently moved from taking about half of the wind energy provided to now almost two-thirds. I believe by this time next year all the technical and legal issues will be worked out and we will have the very wind farm – water system we envisioned.

Lālāmilo is a wind and water system that works with complete synchronicity delivering customer savings while improving the environment for our island.

As the Water Department mission mandates: “DWS’s mission is to provide affordable water service to the people of Hawai‘i Island. In April 2011, DWS established an energy policy to reduce energy use and its associated costs and environmental impacts. The Lālāmilo windfarm is consistent with this policy and is expected to save DWS customers $1.0 million per year in energy costs over the next 20 years.”

Hawai’i sustainability – past, present, and future

With an ancient legacy of leadership in practical sustainability on a remote archipelago; an ongoing progression of intended results crystalizes when we align vision with performance and continuous learning.

The Lālāmilo Wind Farm was conceived and achieved from this type of vision, performance and efforts from a Water Department and a developer with great minds and hearts. I believe that it is necessary to reclaim the Lālāmilo Wind Farm as a living example of what is possible with the right intentions and the right public-private-partnerships in place. That means that like our ancestors, if we match the best of our great local talent with the great innovation from all over the world, we can continue to create remarkable, world-class achievements.

If we continue to encourage these highly-effective and ethical partnerships to flourish, Lālāmilo and other unique Hawai`i-sourced innovations will continue to provide the foundation of a progression toward actual sustainability.

Over the course of nearly a decade of a public servant career with the County of Hawai`i, the Lalalmilo Wind Farm is by far my highest example on what our Island can do when we come together with vision and courage, no matter what inevitable obstacles we face.


Will Rolson is a contributing editor for BeyondKona.com. He served as County of Hawai`i – Energy Coordinator from July 2009 – April 2018.  Will has 33 years’ experience in the energy field as a power engineer, energy analyst and investor. He served the State and County of Hawai`i for the past 11 years, in the capacities of the state’s Renewable Projects Administrator for the Natural Energy Laboratory of Hawaii Authority, and for Hawai’i County, as the county’s Energy Coordinator.

Broken Pv

PUC 2018 Submission — Proposed Customer Self-Supply Rules

The comments that follow are my April 10th 2018 submission to the HPUC, ref: docket 2014-0192.  My submission addressed the HPUC request for public comments whereby Hawaii’s PUC is presently considering a so-called “Customer Self Supply” or CSS ruling that will govern the state’s installed base of residential solar power producers fortunate enough to have previously qualified for (NEM) net metering program, and solar residents and businesses now seeking to add battery storage options, and potentially greater solar capacity (as technology improves and costs drop), but are presently prohibited from making any system improvements or modifications to their installed solar system – solar investments with a lifestyle of 25 – 30 years… 

Background – As a full time resident of Hawai’i, an emissions-free power producer, NEM customer of HELCO, EV owner, participant in the state’s 2045 RPS goal, and with 20 years’ experience in the clean energy market sector, I’m well qualified to speak from experience about the role and opportunity of distributed solar power generation and storage presents to Hawai’i.

Over 15% of residential customers in some areas of Hawaii have rooftop solar. As a result, Hawaii is the first “test case” in the U.S. for high penetration solar.  The large scale adoption of distributed solar and storage across Hawaii’s multi-island network of power grids is a cost effective and energy efficient alternative to the 20th century utility business model and strategy employed by Hawaiian Electric companies.

Faced with declining power sales profits, Hawaiian Electric, through its multi-island utility power monopoly, clamped down on residential solar installations by capping roof-top solar growth in a multi-prong strategy of successfully lobbying the HPUC to end the state’s highly successful net metering program, raising solar-specific rates, and in some cases simply prohibiting residential and business solar installations in Oahu, Maui, and Hawai’i Island.

Instead of Hawaiian Electric upgrading its local grid assets to address the opportunities available to 21st century grid operators employing distributed two-way power flows efficiently, the state’s largest utility instead has systematically deployed a strategy to limit distributed solar growth in Hawai’i, a strategy based on the false premise that power producing utility customers are in fact competitors.  The effect of this HECO strategy, along with the termination of Hawaii’s successful and fair cost sharing NEM program in 2015, has had a major economic impact on the growth of Hawaii’s clean energy solar economy, resulting in less grid reliability – not more, higher rates to consumers, and a grid-based power supply on three of Hawaii’s four major islands that is ill-prepared for the new climate change realities now unfolding across the world.

Customer Self-Supply (CSS) – On March 9, 2018, the Hawaiian Electric utility companies filed their proposed policy and procedure referencing the Commission’s decision and order 34924, issued on October 20, 2017, Docket No. 2014-0192 that allows for NEM customers to add (upgrade) their PV systems with system technology upgrades confined to non-export power applications, e.g., the addition of battery storage to existing NEM customer installations.

HECO acknowledges in their letter to the Commission provisions in which NEM customers may choose to add to their PV system non-export technology components so long as these component “upgrades” include the addition of advanced inverter technology which benefits the utility – an added component cost which is entirely assumed by residential solar energy producers, not Hawaiian Electric.

The CSS guidelines further require NEM Customers to submit to their governing HECO utility for review and approval a request to add non-export technology to their existing NEM system, even though such technical modifications do not impact or otherwise permit additional power supply directed to the grid beyond the original allowable capacity limit and NEM agreement between the Customer and HECO establishing customer power generation limits back to the grid — in effect, the CSS NEM customer system modifications are limited to power generation-storage purposes other than supplying power to the utility grid.

Operationally, NEM customers that add battery storage or added PV production capacity, as the rules are written, are restricted to a non-export customer site battery charging application, with no operational effect or impact on HECO power management and load balancing requirements of the utility’s grid.

The Commission should ask itself, under current CSS rules why HECO has the right to dictate and place requirements and costs on NEM customers that pertains to private property and self-supply power assets owned and operated for personal use that is technically firewalled from the utility grid operation.

An argument can be made that CSS is analogous to off-grid residential property owners who generate, store, consume and manage their own power management assets for their own purposes in which no such requirements apply.   This is a legal question concerning the CSS rules which have yet to be tested.

Recent events in Hawai’i and around the world have placed power security at the forefront of power consumer concerns. Traditional grid operators, like HECO utilities, are cases in point.  HECO has failed to learn from recent extreme weather events around the world, and more specifically, Puerto Rico, that 20th century design centralized power grid operations fail the resiliency test and demands of 21st century climate change.

The reliability of electricity supply systems is generally measured using two metrics that show the duration and frequency of outages. The US Energy Information Administration reported interruptions in electricity service vary by frequency and duration across the many electric distribution systems that serve about 145 million customers on the United States mainland.  In 2016, customers experienced an average of 1.3 interruptions and went without power for four hours or more during the year.  Outage frequency and duration values are reported to EIA for any interruption lasting longer than five minutes. Utilities may designate if these outages occurred during major events, which in the case of Hawai’i can include hurricanes, floods, wind storms, or heatwaves.

Here on Hawai’i Island HELCO has demonstrated itself to be an unreliable power provider partner. Shortly after completing a year-long effort (at ratepayers expense) to harden its operating grid from Waimea to Kona, Hawai’i Island was hit with a wind storm (not even a Cat 1 force storm) on October 24, 2017 that resulted in power disruptions in North Kona of more than 5 hours, and in four other locations around the island, including parts of Hilo.  HELCO’s 2017 power reliability record for Hawai’i Island included extended power disruption events (planned and unplanned) followed by local headlines that read:

10-24-17          Storm knocks out power to 4,600 HELCO customers on Hawaii Island

10-5-17           Over 2,000 HELCO customers lose power in North Kohala

09-21-17          HELCO scheduled 10 hour power outage in North Kohala

07-28-17          HELCO power outage due to Keahole power plant tripping offline

Can Hawai’i Island residents and businesses trust their utility to be there when needed in the time of an emergency?  If recent events in Puerto Rico and other island communities are any guide, Hawai’i power consumers face even greater uncertainty in the utility’s readiness based on a fragile centralized power delivery structure that fails to address the challenges of future climate change-driven super storms.

Utility customers today, and without any special utility permitting process, may install on their property a gas-powered stand-by generator to serve as a power security backup in the event of a utility power service failure. Home generators, however, have a limited operating duration: for the average home and fuel supply, and other limitation factors, a continuous emergency energy supply from gas-power back-up system are is generally limited to 8-to-12 hours operating duration. PV and battery storage systems in many cases can provide non-stop, whole house auxiliary power for up to one week, possibly longer, preventing economic and social disruptions for Hawai’i residents and businesses as the centralized grid recovers and restores customer power.

If power security is important to the residents and businesses of Hawai’i, and who would argue otherwise, then the installation of roof top solar coupled to batteries, connected or not connected to the grid are the primary missing links in Hawaii’s journey to achieve a 100% reliable and renewable clean energy economy that is diversified, distributed, robust, resilient, cost and technology effective.  The CSS rules fall short in achieving this essential transition.

In summary — from direct experience over the past 6 months in qualifying and performing technical and regulatory due diligence with solar / battery contractors in an attempt to upgrade and add on-site battery storage and production capacity to our legacy NEM PV system installation, I have discovered firsthand how the CSS requirements can place an unreasonable burden of time and money investment on NEM solar customers seeking power security and greater self-generation power efficiencies, while furthering Hawaii’s clean energy economy and independence from fossil fuel.

What HECO and the PUC so far have failed to address is the opportunity for a changing utility business model that embraces grid service ahead of power generation revenues, and the important role the grid can play in power back-up and power management among all of Hawaii’s power stakeholders.

CSS as currently developed adds unnecessary barriers of entry for existing NEM customers: layers of bureaucracy and unnecessary costs to roof top solar participants in Hawaii’s clean energy economy. Instead of rearranging the chairs on the Titanic, the Commission should look to California and other advanced and progressively regulated clean energy markets for lessons already learned and the merits in advancing distributed power opportunities for the public benefit.

Bill Bugbee


Principal, Globetrans-ec


Kailua-Kona, HI  96740

High Cost Of Water

Hawaii County’s High Cost for Water and Power

Electric utilities face many challenges today. Hawaii Electric, and utility operating unit Hawai’i Island (HELCO) continue their primary fuel source reliance on unsustainable fossil fuels to produce power for their grid customers, and Hawai’i Island’s water utility, DWS is HELCO’s number one customer and largest power consumer. But as renewable and distributed power generation sources like solar and wind come online, former residential and business power consumers become clean power producers with multiple benefits to society – and by extension to HELCO.  The choice between imported, dirty power versus locally produce zero emissions clean power is obvious to everyone, except those with a vested interest in the status quo. Utilities with little accountability to energy costs (which are passed onto customers) have little incentive for advancing clean energy options and the social, economic, and environmental benefits they yield.   Read more

PUC “Public Comment – Docket No. 2014-0183 – PSIPs”

The Honorable Chair and Members of the Hawai’i Public Utilities Commission
465 South King Street
Kekuanaoa Building, 1st Floor
Honolulu. Hawai’i 96813

Subject: “Public Comment – Docket No. 2014-0183 – PSIPs”

Dear Commissioners,

Hawaii Electric Light Power Supply Improvement Plan of August 2014 submission fails in several fundamental ways to provide the people of the state of Hawaii a path to fossil fuel-free energy future, one that can be completely powered by clean and renewable energy sources. Read more