The Hawaii Division of Consumer Advocacy requests a second extension of time to file a motion for reconsideration of a Public Utilities Commission decision regarding Hawaiian Electric Companies' Tariff Rule 14H. The extension is requested to allow more time to evaluate issues raised by a Maui Electric customer and further clarify Maui Electric's responses and procedures. The Division seeks the extension to determine if a motion for reconsideration is necessary.

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
www.hawaii.gov/dcca/dca
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. 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. 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. 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. 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. 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
www.hecofitio.com.
Thankyou,
Justin Goza
Maui Electric Company, Ltd.

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. 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. 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.