The letter expresses frustration with MECO's vague response requiring an Interconnection Requirements Study (IRS) costing $3,000 for Lawrence Lee's small 3kW residential PV system without clearly explaining the reasons or providing data. Lee argues MECO is not judging each system on its own merits as intended by recent PUC rule changes. He requests specifics on what technical issues were identified during review to warrant the IRS, and questions if all similar systems will face the same requirement and costs.

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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

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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

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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.