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

Noel Morin

Big Island EV Ownership – as easy as plug and play


Ev Event Kona 2016

On the Big Island, we’re seeing a consistent growth of electric vehicle adoption. They still represent less than 1% of the roughly 185,000 passenger vehicles on Hawaii Island’s roads, but also represent a 30% growth year-over-year for the past 3 years — we’re now at around 440 electric vehicles.

EV growth is being inspired by the availability of lower priced long- range electric cars and better consumer awareness. The Tesla Model 3, Chevy Bolt, and Nissan Leaf are especially popular – they’re becoming a common sight on our roads. Soon-to-be available mid-$30,000, 200-mile vehicles like the Kia Niro and Hyundai Kona EV, and Tesla Model 3 (the lowest price version) will escalate adoption even more.

For Big Islanders who need a truck, EV pickup options are in the works from companies like Telsa, Bollinger’s B2 and Rivian’s R1T:

Tesla Truck

B2 Ev Truck

Rivian R1 Truck



Most people understand the performance benefits of EV’s, but a not too big secret among EV owners readily known inside the community is the low cost of EV ownership.   Electricity is much cheaper than gas, and EVs are highly efficient. But missing in the bigger picture of owning an EV beyond the immediate purchase cost is that electric cars require very little operating maintenance. There are virtually no fluids to change, fewer working parts, and electric motors tend to work for a very long time without any routine upkeep. EV’s are generally powered by only 15-20% of the parts that an internal combustion engine (ice) truck, SUV, or car — ICE vehicles also require repeat and frequent maintenance not associated with electric vehicle operation.

EV owners rarely visit their vehicle dealership for maintenance, a savings of both time and money. By example, the Chevrolet Bolt requires almost zero maintenance for the first 150,000 miles.



Increased adoption of electric vehicles in Hawai’i is a bright spot; however, it is not without risk and future headwinds.  In achieving a sustainable economy and environment for Hawai’i, Electric Vehicles are only one part of the solution – in order to reduce our oil dependence, we must address the broader system including energy production and consumption.  Energy production is a very relevant part of the discussion in addressing sustainability, because the nature of the energy used to charge an electric car will have a big impact on its carbon footprint.  An increasing number of Big Island electric vehicle owners power their cars from roof top solar installations on their homes and businesses, while other EV owners are wholly dependent on the grid.

The Big Island’s energy grid operated by HELCO is still largely dependent on fossil fuel – approximately 50% of HELCO’s electricity generation was (until recently) sourced from renewable sources, and prior to the loss of the Puna Geothermal Venture. PGV, and its 38 MW power generation, is now out of commission since the Kilauea eruption of 2018 disrupted operations – possible permanently.

HELCO has taken steps to increase its renewable portfolio, but only recently has recognized and publicly acknowledged the value of utility scale solar and storage as replacement for its diesel powered plants. Hawai’i state, and more specially our island utility, must do more towards fulfilling its 100% renewable energy obligation to the state 2045 mandate and the growing number of EV’s across Hawai’i Island, and the state.

The urgency of our climate crisis is at the highest level ever. Reports released by Intergovernmental Panel on Climate Change earlier this year indicate that our climate has deteriorated more than previously reported and that many of the things that we’ve feared as a distant reality (mass suffering and economic chaos as a result of destructive sea level rise, coral reef temperature extremes, more frequent superstorms and fires,) are just around the corner.

This year’s disasters – super hurricanes and typhoons and wild fires in North America and Europe are undeniable signs that we’re in the midst of a new climate reality. This is a very unfortunate reality, particularly for our future generations. However, we act with even more urgency to address the root causes of the crisis.

Addressing carbon emissions, a major greenhouse gas and root cause, must continue to be a major strategy in combating climate change. U.S transportation contributes to about 30% of our carbon emissions while motor vehicles contribute to 20% (https://www.ucsusa.org/clean-vehicles/car-emissions-and-global-warming#.XBaj2C2ZM0o). Thus, a meaningful shift away from carbon-emitting transportation is key to mitigating climate change.

Electric vehicles play a significant role in mitigating climate change.

Based on statewide averages, the amount of fossil fuel used to power an electric vehicle in Hawaii is 31% less than the fossil fuel required to power a similar gasoline-fueled vehicle. This is expected to get even better as renewable energy increases in Hawaii.   Today, transportation represents over 40% of global warming emissions; EV’s are zero emissions transportation.

Together with a 100% renewable energy grid, they will enable significant reduction in our dependency on fossil energy and cutting back of carbon emission. We’re fortunate to be witnessing the tipping point for electric cars – consumers are finally seeing their experience and environmental benefits and manufacturers are responding.

Shifting to electric passenger vehicles, buses, freight trucks, and migrating our energy grid to truly home grown renewable sources – must be done as soon as possible.    Consumers can encourage the shift by publicly expressing their demand for actions that are consistent with our sustainability goals, e.g., express concern about the carbon impact of the biomass peaker plant in Hamakua, demand rooftop solar, express support of policies that serve to incent PV and EV adoption, and support the Carbon Fee and Dividend legislation.

Fortunately, markets across the globe are responding. Several countries and communities have committed to aggressive plans towards renewables and the electrification of transportation. Importantly, electric vehicle adoption continues to grow aggressively, and manufacturers are responding to the demand with the delivery of new electric vehicle options and promises of eventually deprecating fossil fuel burning powertrains.

The EV field is now getting crowded with options – many more form factors and price points.  As a result of battery technology innovations and economies of scale, long range electric vehicles are now becoming price-competitive with comparable gas or diesel models. We’re also seeing affordable pre-owned inventory grow – these represent very affordable buying options for consumers.

To learn more about electric vehicle ownership on the Big Island, visit http://www.bigislandev.org/.

Hawai’i EV Registrations by Island

Ev Hawaii Registration 2016


Hawaii’s Electric Vehicle Laws and Incentives:

  • Free parking is provided in state and county government lots, facilities, and at parking meters. (Act 168 of 2012, Hawaii Revised Statutes, 291-71, Note)
  • Parking lots with at least one hundred public parking spaces are required to have at least one parking space, equipped with an EV charging system, reserved exclusively for EVs. (Hawaii Revised Statutes 291-71)
  • Non-EVs parked in a space designated and marked as reserved for EVs shall be fined not less than $50 nor more than $100. (Hawaii Revised Statutes 291-72)
  • Hawaiian Electric Co. offer EV Time of Use Rates designed to incentivize customers, through lower rates, to charge their EVs during off-peak times of day.
  • Multi-family residential dwellings or townhomes cannot prohibit the placement or use of EV charging systems altogether. (Hawaii Revised Statutes, 196-7.5)
  • Vehicles with EV license plates are exempt from High Occupancy Vehicle lane restrictions. (Act 168 of 2012, Hawaii Revised Statutes, 291-71, Note)


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.

Ev Pic

PUC 2018 Submission — Hawaii’s Electrification of Transportation

Public Utilities Commission of the State of Hawaii

Honolulu, HI 96813


Docket No. 2018-0135   –   Electrification of Transportation


Dear Commissioners:

Hawaiian Electric (HEI) faces unique challenges when it comes to cost effectively developing and/or supporting an EV charging infrastructure within the utility’s multi-island service territories, and at the same time address a diverse set of transportation EV powering requirements – a challenge that is multiplied by the number of islands, different population densities, island-specific geography, social, and economic diversity.

For example, Oahu, with its 1.1 million densely packed population within 600 sq. miles, and nearly 900,000 registered vehicles, presents a very different EV infrastructure challenge and opportunity compared to Hawai’i Island’s 220,000 residents who are spread over 4,028 sq. miles – an area representing almost 63% of the entire state’s land mass, and with slightly less than 200,000 registered vehicles.  These differences represent more than just a challenge of scale to HEI in any attempt to successful implement the company’s “Electrification of Transportation” (EoT) roadmap and business strategy.

Range Anxiety

Fast, slow, scheduled and unscheduled, compatible and incompatible, available and mostly unavailable, members only or open to anyone with a charge card, Hawaii’s EV drivers face these decisions daily that define the current EV charging landscape. These charging access obstacles historically have constrained the market growth of EV’s in Hawai’i and provided some confusion for newly initiated EV owners.

When electric vehicles entered the market nearly a decade ago, most manufactures (except Tesla) offered vehicles with very limited range, generally, less than 90 miles range.  In the last few years, EV range limitations have begun to evaporate; going from under 100 miles to 200 plus miles, and more recently 300 plus miles driving range between charges.  Longer range EVs now entering the market represent a paradigm shift away from past EV assumptions and driver charging options and habits.

All this raises an important question, with battery price and performance efficiency improving exponentially; does Hawai’i need an EV charging station on every corner?   The HEI EoT roadmap strategy appears weighted on historic assumptions and past EV driver behavior patterns – a mistake.

Historically, EV drivers with short-range battery powered vehicles have been forced to top-off with frequent charging to overcome perceived or real driving range anxiety and the absence of charging options, yet what percentage of Hawaii’s internal combustion engine (ICE) drivers stop off at their neighborhood gas station daily just to top off their fuel tank?   Over the next five years, EV passenger cars, SUV’s, pick-ups, and commercial trucks will feature 500-600 plus miles driving ranges and on a single charge.  In building out Hawaii’s EV charging infrastructure, the stakeholder planning process should fully consider that many future EV drivers will follow the same charging pattern they now engage in with their ICE vehicles, but instead of visiting a gas station weekly to fuel up, these EV drivers will be fast charging their vehicles once a week, and at places much more convenient than area gas stations, e.g. at home or work.

VHS Versus Beta – Speed Versus Scheduling

At the moment, Tesla and carmakers in Japan and Germany use different plugs and communication protocols to link batteries to chargers, but firms building the charging networks require electric vehicle manufacturers and utilities to limit the number of plug and charging formats needed in order to keep costs down and enable large scale deployment of vehicle charging stations.

Currently, and for the near future, EV’s will support (across vehicle manufacturers) two common charging methods; 1) Level 1 standard, 120V wall plug outlet (slowest charging method), and the faster Level 2 public charging station protocol now widely available (twice as fast as Level 1).

For the average daily EV driver or commuter, access to a Level 2 charging station at their place of residence or office is sufficient to meet daily transportation needs. By example, an overnight with an in-residence L-2 charging station will fully recharge an EV with 90 KW battery and delivering to the driver a 250-300 plus mile driving range – much more range than is needed for nearly all daily needs on any of Hawaii’s islands.

The public is already engaged in overnight charging of their phones and other devices; plugging in their EV overnight at home or during the day at work is no different in terms of an acquired habit.

Tesla’s fast Super Charger network in the US, Europe, and Asia is currently the gold standard for fast charging and for wide scale network implementation across multiple countries.  While sticking with developing its own proprietary network for now, Tesla is a member of the CHAdeMO and CharIN initiatives. It is also selling adapters so owners of its cars in North America and Japan can use CHAdeMO (Level 3) charging stations.    Most current CHAdeMO chargers offer charge speeds of 40 – 60 kW, which is fast enough to charge a Nissan LEAF to 80 percent in about a half hour.

The fastest DC stations now deliver up to 400 kilowatts and can fully recharge long range EVs within 10 minutes, a vast improvement over Level 2 AC charging stations common today.  However, faster and really fast EV charging is no longer the exclusive domain of government regulators, and left to the marketplace where different and competing manufacturer priorities are battling for market definition and dominance, in effect competing not through EV innovation and advanced technology, but over EV plug types and charging formats.

Faster and shorter charging times will continue to improve, however, technology limitations and competitive interests among the stakeholders have so far constrained opportunities for a standardized very fast charging solution available across multiple vehicle platforms.  Until the marketplace settles on an universal and very fast charging standard, by extension, the fulfillment and promise of V2G vehicle power sharing, load balancing, on-demand power prioritization between EV’s and the grid will remain mostly limited to EV vehicle fleet operations, and not available to the general public.

Transformation or Adoption

The biggest growth opportunity for electric utilities in the 21st century continues to be the transformation and electrification of transportation, not only here in Hawai’i, but around the world.

All efforts undertaken by HEI to interface and otherwise co-develop with third parties within the EV market and technology sectors, including vehicle manufacturing leaders, e.g., Tesla, BMW, GM, Nissan, and others, along with charging station vendors and software companies and in the fulfillment of the company’s EoT strategy, should be encouraged.

Potential stakeholders, and the public is the major stakeholder in this case, should also be encouraged and enabled by the PUC to fully participate in Hawaii’s emerging clean energy economy and EV transformation.  As for business and technology sharing efforts between HEI and other third parties companies, this activity should be not be subsidized by HEI ratepayers, as this activity would be principally designed to serve HEI’s business development interests, rather than its regulated power provisioning activities.

The EoT strategy outlined in the HEI submission to the PUC fails in its assumption that time-of-use charging by EV owners will be weighted towards and a preference for, daytime charging that especially  benefits HEI during peak solar generation periods. The primarily beneficiary of day-timed charging will be HEI profits and operations, not necessarily the EV driving public.

HEI EoT roadmap submission does not address the current deficiencies within the PUC’s Distributed Energy Resources docket 2014-0192, nor the obstacles the subject docket and companion rulemaking dockets represents in the form of barriers entry in the advancement of distributed roof top solar and storage. This is specifically true for Hawaii’s large and multi-island installed base of NEM solar power producers – many whom already are or will be future EV owners.  For further elaboration on this point, please see our comments submitted to the PUC and dated April 8, 2018, re docket 2014-0192.

HEI further fails to address the basis for its EoT key assumption, “…Little is wasted because ground transportation and energy use are linked to optimize daytime charging and to use EVs as a key grid service resource”.  As this certainly is possible, it’s a stretch to assume the general EV driving public will fully accommodate HEI’s daytime charging expectations, while at the same time the HEI roadmap fails to recognize the realities of human behavior, charging convenience, and charging costs to EV owners.

For many EV owners, home charging overnight and while you’re asleep could not be more convenient. In the case of HEI customers under a NEM contract and not bound by TOU (time-of-use) restrictions, it is not only convenient, but a cost effective vehicle charging strategy.  Every link in the power supply chain, from grid-to-vehicle, adds cost, and the more links in that supply chain, the higher the charging cost to EV owners.

Without subsidization of EV charging stations and lower power costs passed onto the end EV consumer, the necessary EV owner charging behavior assumed by HEI and needed to optimize their day charging assumptions seems doubtful.  Even if EV charging station power rates were subsidized to encourage large scale TOU participation with HEI’s daytime charging model for optimizing its grid operations, who will pay for this subsidy of EV power rates?

Is the public to be held hostage over future issuance of utility roof top solar permits if HEI’s plan fails in its EoT plan assumptions?  Instead, HEI should be adopting utility scale solar and battery storage that will address and scale to peak solar production output opportunities in meeting the company’s 2045 RPS clean power source obligations – and begin that change now by looking no further than to Kauai’s successfully KIUC utility-scale deployment of clean energy options coupled to battery storage.

Many of the questions raised in this submission to the Commission can be addressed by opening up the regulated portions of Hawaii’s power market to distributed and emissions-free (2045 RPS compliant) individual clean power producers; primarily defined as Hawaii’s roof top solar power producers and customers of HEI, as well as future EV owners.

A major shift in HEI’s operating / revenue model from power producer to grid and power manager is long overdue and necessary to fully enable Hawaii’s EV transportation options.   So far, the Hawaii’s PUC has only made tentative steps towards needed reform, and the PUC’s late, but welcome, regulatory acknowledgment and opening role for micro grids in Hawai’i will further advance the state’s clean energy economy and the development of a diversified EV charging infrastructure designed to serve the public.    The public and HEI can be effective partners in Hawaii’s personal and commercial electrification of transportation – a transformation already underway, and one that is occurring regardless of the degree of financial benefit to HEI.

For HEI to fulfill its lofty 2045 vision statement within its EoT roadmap, HEI and the state of Hawai’i must address the realities of driver behavior coupled to the power of convenience, and the cost of power to consumers who can choose how to power their homes and businesses, and soon their vehicles as well.

Thank you for your consideration of these comments.




Bill Bugbee

BeyondKONA, LLC.


Kailua-Kona, Hawai’i  96740

Shell Euro Ev Charging Station



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