Lawrence lee meco


Published on

Published in: Technology, Business
  • Be the first to comment

  • Be the first to like this

No Downloads
Total views
On SlideShare
From Embeds
Number of Embeds
Embeds 0
No embeds

No notes for slide

Lawrence lee meco

  1. 1. NEIL ABERCROMBIE KEALIl S. LOPEZ GOVERNOR DIRECTOR BRIAN SCI-IATZ LT. GOVERNOR JEFFREY T. ONO EXECUTIVE DIRECTOR STATE OF HAWAII DIVISION OF CONSUMER ADVOCACY DEPARTMENT OF COMMERCE AND CONSUMER AFFAIRS 335 MERCHANT STREET, ROOM 326 P.O. Box 541 HONOLULU, HAWAII 96809 Phone Number: 586-2800 Fax Number: 586-2780 January 31, 2012 The Honorable Chair and Members of the Hawaii Public Utilities Commission Kekuanaoa Building 465 South King Street, 1st Floor Honolulu, Hawaii 96813 Dear Commissioners: RE: Docket No. 2010-0015 — Consumer Advocate’s Second Request for Enlargement of Time to File Motion for Reconsideration or Clarification. The Division of Consumer Advocacy (“Consumer Advocate”) respecifully requests a second enlargement of time for the Consumer Advocate to file a motion for reconsideration or clarification of the Decision and Order (“Decision”) filed December 20, 2011 in Docket No. 2010-0015. The Consumer Advocate makes this request pursuant to Section 6-61-23(a) of the Hawaii Administrative Rules, Title 6, Chapter 61. The Consumer Advocate seeks this second enlargement of time to file a motion for reconsideration or clarification to allow additional time to further evaluate whether a motion for reconsideration or clarification is necessary. As proffered as good cause for the Consumer Advocate’s initial request for enlargement of time noted that the Decision raises numerous regulatory issues, specifically as it relates to the Public Utilities Commission’s findings associated with the Hawaiian Electric Companies’ Tariff Rule 14H, Appendix I, Section 2g. Recently, an inquiry from a Maui Electric Company, Limited (“MECO”) customer instigated further evaluation of issues associated with the approved tariff language, clarity of the Hawaiian Electric Companies’ procedures,
  2. 2. The Honorable Chair and Members of the Hawaii Public Utilities Commission January31, 2012 Page 2 and broad-reaching impacts on the provision of reliable electric service, cost to ratepayers and the potential curtailment of existing renewable energy generators. On or around January 15, 2012, the Consumer Advocate received an inquiry from a MECO customer, Lawrence Lee.1 The Consumer Advocate informally inquired with MECO to seek clarification of the facts and assertions provided by Mr. Lee.2 The Consumer Advocate seeks additional time to further evaluate the interpretation and possible related tariff and consumer impacts of the Decision considering the comments presented by Mr. Lee and relative MECO responses. To date, the Consumer Advocate is continuing to seek further clarifications from MECO. Accordingly, the Consumer Advocate requests a second enlargement of time from January 31, 2012 through February 21, 2012 to allow additional time to conduct its investigation and further analyze the Decision in order to determine whether there may be a need to file a motion for reconsideration or clarification.3 The Consumer Advocate has not surveyed the parties in this docket to determine whether there will be any opposition to this request.4 See attached, letter from Lawrence Lee, dated January 15, 2012 via electronic mail. 2 See attached, MECO letter, dated January 12, 2012. The timing for the filing of a Motion for Reconsideration (or clarification) and an accompanying Memorandum is governed by Hawaii Administrative Rules (“HAR”) § 6-61-22 (computation of time), § 6-61-21(e) (service of process), and § 6-61-1 37 (motion for reconsideration or rehearing). The prescribed period for filing a motion for reconsideration is ten (10) days after being served the decision or order. If the decision or order is served by mail, a party is entitled to two additional days to respond. In the instant case, the Decision and Order was filed on December 20, 2011 and served upon the parties by mail — received by the Consumer Advocate on December 21, 2011. Thus, the prescribed period to file a Motion for Reconsideration and/or Clarification ends on Saturday, December 31, 2011 with an additional two days extending the deadline to the next business day, Tuesday, January 3, 2012. The Parties in this proceeding include the Hawaiian Electric Company, Inc., Hawaii Electric Light Company, Inc., Maui Electric Company, Limited (collectively referred to as the “Hawaiian Electric Companies”), the Department of Business, Economic Development and Tourism, Blue Planet Foundation, Hawaii Inspection Group, Inc., Hawaii PV Coalition, Hawaii Renewable Energy Alliance, Hawaii Solar Energy Association, South Maui Renewable Resources, LLC, The Solar Alliance, Zero Emissions Leasing LLC, Participant Interstate Renewable Energy Council, and the Consumer Advocate.
  3. 3. The Honorable Chair and Members of the Hawaii Public Utilities Commission January 31, 2012 Page3 JTO:dl Thank you for your consideration of this request. Enclosure rrey T. Ono Executive Director cc: Service List
  4. 4. ATTACHMENT Page lof3 January 15, 2012 Jamie and Justin, As you know, I have received a copy ofthe letteryou sent to Shelby at American Electric regarding my application for net metering/ grid interconnection of my 3kW residential PV system at 297 MakaHou Loop in Wailuku. This letteris to notify you that I intend to proceed withthis project. Unfortunately, the letter you sent leavesme with more questions than answers. The letteris obviously a rubber-stamped form letter. (You forgot to remove “Incorporated” from the re: line, and to take the “s” offof installations and project~from the lasttime you used the letter.) It speaks onlyin excessively general terms, does not address myproposed system specifically on its own merits, and fails to provide me with any substantive information or data. Jamie, you told both Jan Lattimer and myself that since my application was the very first in line tobe evaluated based upon the new 14H revisions, and because it is such a small system, approval “should notbe a problem”. Now it appears my application is being lumped together with all of the installation,~ and project~coming in for evaluation. Justin, during your conversation with Jan Lattimer on Friday last week,Jan asked you why such a small system is a problem. Your replywas “If weapprove all ofthe small systems it will be a problem”. Jamie, you told me that every individual system would be judged on it’s own merits and on a first-come, first-considered basis. It appears that this is nothappening. I should have beentold the results of the Initial Technical Review screenings. Which screenings did my proposed system fail? It would appear that you are saying an IRS is required, although you never actually say it. You use terms like “more detailed study” and “minor study” butyou never actually say IRS or Interconnection Requirements Study. IfI am being required to perform an IRS, I shouldhave been providedwith details about the specific analysis and/or reviews that willbe performed as part of the IRS. Also, what specific findings during the supplemental review process triggered the need for the IRS? Instead ofbeing specific, you list “several potential issues” that are unreasonably general and broad in scopeand could be applied to the grid interconnection of any DG system. Additionally you provideno supporting dataor details. Are you goingto require everyone who wants to install a systemand fails screen4 toperform the same studyyou are requiring me to do? Will they receive the same form letter you sent me? IfI pay forthe IRS and get approval, will my next-doorneighborhave topay for a study as well ifhe wants to install the same exact system? And will his next-doorneighborhave to do the same? Would you please tell me, at the time of my supplemental review, what was the aggregate DG capacity on my line section. Also, what are my line section’s peak load and “solarnoon” minimum load? The data you post on your Web site indicates that my streethad not yet reached 10% penetration as of September 2011. I have the rightto know exactly what was done during the supplemental review process. What
  5. 5. ATTACHMENT Page 2 of 3 spec~ficallydidyour review find that makes this IRS necessary? Whatmeasurements were taken? What datawas reviewed? What calculations were done? I would like to get a copy of the final supplemental review reportso that I can seewhat prompted the need forthe IRS. Jamie, you told me that my applicationwas the very first on Maui to go across your desks be evaluated based on the new PUC revisions to tariffrule 14R. It seems to me that what I am goingthru now is exactly what the PUC’s revisions to 14H were supposed to prevent. How are things different from the way they were before the Commission’s ruling? Allthe hype about the revisions facilitating increased penetration, yet not even one additional tiny 3kW PV system is being allowed to interconnect on my line section withoutperforming an IRS. You know that most people will not be willing to roll the dice with $3,000.00 on the line knowing that you (MECO) control the outcome ofthe roll and canmake the dice land on any number you want.You are asking me to pay $3000.00 for a consultant’s studywithout tellingwho the consultant is, without telling me specifically what will be studied, without giving me any specific supporting datato show why you deemed it necessary to perform an IRS , and without telling me what results willbe required from the study formy application to be approved. To make matters worse , you tell me to “Keep in mind that this study could determine that a full studyis required, and could cost approximately $30,000.” It would appearthat you are doing your best to make me walk away from this project. Apparently, the 15% “virtual ceiling” has not really beenremoved, despite all the PUC press releases, Governor’s speeches, and newsreports that say ithas. It would appear that HECO has successfully duped everyone. In my opinion, every concern you listedin your letterabout the interconnection ofmy system to your grid is unreasonably broad inscope or should have been specifically addressed inthe supplemental review process using the drawings, data sheets and other information you specifically required at the time of application. It appears that my systemis notbeing judged on its own merits or on a first-come first-consideredbasis. I do not believe any additional study shouldbe required for approval of my small 3kW PV systemif it isjudged on its own merits and you use currently available data. I am asking you to reconsider your decision to require an IRS, to do the right thing, and approve the interconnection of my system based on the the merits of this one installation alone, just as the PUC intended you to do when they revised 14H. I look forward to hearing back from you, having my questions answered and receiving the information I have requested. Sincerely, Lawrence Lee 808-268-2949
  6. 6. ATTACHMENT Page 3 of 3 Maui Electric Company, Ltd. • P0 Box 398 • KahulUl, HI 96733-6898 January 12, 2012 Lawrence Lee Attn: Shelby Ahwah Re: NEM project Lawrence Lee Incorporated Dear Shelby: Regarding the 2.94 kW PV installations proposed at 297 Maka Hou Lp. inWailuku, Maui Electric Company (MECO) has completedthe supplemental review and determined that a moredetailed study is required. There are several potential issues withthe interconnection of the proposed project on the MECO system. The reliability and safetyissues identified include ground fault, overvoltage concerns, transformer sizing, harmonic current levels, harmonic voltage distortion, and circuit PV penetration. Further review will be necessaryto determine the outcome and/ormitigation options. We have contacted a consulting firm to obtain costs forcompleting this study. Theminor study of the system (including consulting and MECO internal costs) is estimated tobe completed at $3,000. Keep in mind that this study could determine that a full study is required, and could cost approximately $30,000. Please contact me at (808) 872-3293 to discuss the details of this determination. Ifyou would like to continue with these projects, please notify MECOwithin 15 business days of your intentto proceed. For the FIT project this may be done by posting correspondence to your “My FIT Docs” folder at Thankyou, Justin Goza Maui Electric Company, Ltd.
  7. 7. SERVICE LIST (Docket No. 201 0-001 5) I hereby certify that a copy of the foregoing was duly served upon the following parties, by personal service, hand delivery, and/or U.S. mail, postage prepaid, and properly addressed pursuant to HAR § 6-61-21(d). DEAN MATSUURA 2 Copies MANAGER, REGULATORY AFFAIRS by hand delivery HAWAIIAN ELECTRIC COMPANY, INC. P.O. Box 2750 Honolulu, Hawaii 96840 DAVID M. LOUIE, ESQ. I copy DEBORAH DAY EMERSON, ESQ. by hand delivery GREGG J. KINKLEY, ESQ. DEPARTMENT OF THE ATTORNEY GENERAL STATE OF HAWAII 425 Queen Street Honolulu, Hawaii 96813 Counsel for Department of Business, Economic Development and Tourism ESTRELLA A. SEESE I copy ENERGY PROGRAM ADMINISTRATOR by U.S. mail Department of Business, Economic Development, and Tourism P.O. Box 2359 Honolulu, Hawaii 96804 DOUGLAS A. CODIGA, ESQ. I copy SCHLACK ITO LLLC by hand delivery Topa Financial Center 745 Fort Street, Suite 1500 Honolulu, Hawaii 96813 Counsel for Blue Planet Foundation
  8. 8. THOMAS J. DOUMA I copy PRESIDENT by U.S. mail HAWAII INSPECTION GROUP, INC. P.O. Box 60 Kihei, Hawaii 96753 BRAD ALBERT I copy PRESIDENT by U.S. mail HAWAII PV COALITION P.O. Box 81501 Haiku, Hawaii 96708 WARREN S. BOLLMEIER II I copy PRESIDENT by U.S. mail HAWAII RENEWABLE ENERGY ALLIANCE 46-040 Konane Place, #3816 Kaneohe, Hawaii 96744 ISAAC H. MORIWAKE, ESQ. I copy EARTHJUSTICE by hand delivery 223 South King Street, Suite 400 Honolulu, Hawaii 96813-4501 Counsel for Hawaii Solar Energy Association JACK R. NAIDITCH I copy CHIEF EXECUTIVE OFFICER by U.S. mail SOUTH MAUI RENEWABLE RESOURCES, LLC 8 Kiopaa Street, Suite 103 Pukalani, Hawaii 96768 SANDRA-ANN Y.H. WONG, ESQ. I copy ATTORNEY AT LAW, A LAW CORPORATION by U.S. mail 1050 Bishop Street, #514 Honolulu, Hawaii 96813 Counsel for The Solar Allllance
  9. 9. CARRIE CULLIN HITT I copy PRESIDENT by U.S. mail THE SOLAR ALLIANCE P.O. Box 534 North Scituate, Massachusetts 02060 ERIKW.KVAM lcopy CHIEF EXECUTIVE OFFICER by U.S. mail ZERO EMISSIONS LEASING LLC 2800 Woodlawn Drive, Suite 131 Honolulu, Hawaii 96822 KEVIN 1. FOX I copy KEYES & FOX LLP by U.S. mail 436 14 th Street, Suite 1305 Oakland, California 94612 Counsel for Interstate Renewable Energy Council DATED: Honolulu, Hawaii, January 31, 2012.