1. June 11, 2013
Chair Hermina Morita
State of Hawai‘i Public Utilities Commission
Department of Budget and Finance
465 South King Street #103
Honolulu, Hawai‘i 96813
Dear Chair Morita,
On behalf of the undersigned members of the Integrated Resource Planning Advisory Group
(“AG”), this letter is submitted in response to your letter to the AG dated May 15, 2013. Events
subsequent to the May 15 letter, and in particular events at the May 30 AG meeting, compel us to
request that you reconsider the decision not to extend the June 28, 2013 IRP filing deadline.
The HECO Companies, Independent Entity, Consumer Advocate, and AG have all worked hard
to make the IRP process valuable to our state’s energy planning process, and we thank you for
expressing the Commission’s appreciation for our work. However, at the May 30 AG meeting it
became apparent that the most critical step of the process cannot be completed prior to June
28. The HECO Companies’ submittal will be made without the AG, as a group, having
opportunity to review the proposed Action Plan, and without the HECO Companies having
opportunity to consider the AG’s perspectives on its proposed submittal. This threatens to derail
the IRP process. Upon the June 28 filing, the process will necessarily shift from a more
collaborative posture, to the more adversarial procedural posture dictated by Commission rules.
It is crucial that the AG and HECO Companies have the opportunity to work together to review
and refine the proposed Action Plan before it is submitted to the Commission, and before the
process becomes more adversarial. Whether by the excusable neglect of the HECO Companies,
the Independent Entity, or the AG, the initial IRP schedule was delayed and the Action Plan was
not provided to the AG for review before the final AG meeting. We request a four-month
extension for the HECO Companies’ filing, on the basis of such excusable neglect, and to
help ensure that the parties’ work to date is used in a way that is efficient and effective.
While four months may not be enough time to address all of the open questions that remain in
this process, it will allow time (i) for the AG to review and comment on the Action Plan, (ii) for
the HECO Companies to consider that advice and revise the Action Plan where appropriate, and
(iii) for the parties to address several key unresolved questions and issues that have arisen during
the IRP process. For example, under the current deadline, the following issues will remain
unresolved prior to the HECO Companies’ submission:
(1) Nexus between resource plan(s) and action plan(s). As of the May 30 meeting, many
AG members expressed concern and confusion about how resource plans, scenarios,
metrics, and analyses are to be translated into the Action Plan(s). The HECO
Companies, Independent Entity, Consumer Advocate, and AG expended significant time
and effort on developing and reviewing such scenarios, metrics, and other items. Without

2. any opportunity to comment on whether there is an appropriate nexus between that work
and the proposed Action Plans, the undersigned AG members fear that this substantial
work will not be adequately reflected in the June 28 filing.
(2) Hawaii Clean Energy Initiative. At the May 30 meeting, the HECO Companies’
presented a high-level overview of the planned direction for the proposed Action Plan.
However, several aspects of that high-level overview confirm that the IRP process has
run afoul of the agreement between the HECO Companies’ and others memorialized in
the HCEI Agreement and subsequent amendments. For example, the HCEI Agreement
mandates the following loading order: “The parties agree that the maximum possible
use must be made of energy efficiency, demand response and renewable energy. The
utilities shall apply this loading order in the CESP [i.e. IRP] process in determining
the utilities' resource plans to supply the total system load.” Relatedly, the HCEI
Agreement requires that the IRP shall identify fossil needs but that new fossil units
“should be justified primarily by the need to balance and integrate variable
renewable energy generation sources for overall grid reliability.” However, the
process used to date in IRP to evaluate various resource plans (and presumably the
process on which the Action Plan(s) will be based) was not based on this loading order.
Several members of the AG expressed concern that the IRP process relied upon a “firm
energy first” screening process, with variable renewable energy and demand response
applied only in later steps. For example, on May 20, after the Commission’s May 15
letter, Synapse Energy Economics on behalf of the Consumer Advocate submitted a
lengthy statement of comments on the IRP process to date. Among other things, those
comments noted its shared concern with the “firm first” screening steps: “Wind and
solar were given no credit to meeting firm requirements. This is inconsistent with
typical treatment of these resources seen in other jurisdictions and may result in
HECO building more capacity than needed.” The result of the “firm first” loading
order is that the submitted Action Plan will apparently propose to commit capital
expenditures to fuel fossil units to add LNG capability. There is no indication that such
capital expenditures on fossil units will have any benefit for “balanc[ing] and
integrat[ing] variable renewable energy generation sources.”
(3) Unresolved AG questions. On May 6, 2013, the Independent Entity identified several
AG comments/questions that remain unresolved and without response from the HECO
Companies.1
In response to the Independent Entities’ inquiry, the HECO Companies
declined to issue written responses to those questions/comments, on the basis that such
responses “would divert the Companies’ resources at this time from documenting
the analyses and completing the filing by June 28, 2013, and could diminish the
quality of the IRP Final Report and Action Plan.” The subsequent May 20 Synapse
Energy comments will presumably also remain unanswered in whole or in part.
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1
Cf. Framework at 9: “Advisory Group members may request that the Independent Entity seek a
response from, or make a recommendation to, the utility concerning any issue relevant to this framework.
The Independent Entity may, at its discretion, present these questions or recommendations to the utility as
appropriate. The utility shall respond in writing and the Independent Entity shall, in turn, share such

3. (4) Resource Plans. The IRP Framework defines “Resource Plan” as “a set of resources,
programs, or actions over the twenty (20) year planning horizon resulting from the
analyses performed for the Scenarios developed during the integrated resource planning
process governed by this framework.” The Framework also specifies that “[t]he utility
shall develop Resource Plans and an Action Plan in consultation with Advisory
Group(s), the public, and the Independent Entity, subject to the oversight and
approval of the Commission,” and that the Resource Plans must be submitted to the
Commission.2
Although the AG was provided with the numerous excel spreadsheets that
were created by the HECO Companies’ during the analyses performed for the Scenarios,
the AG has not been presented with definitive Resource Plans for comments “resulting
from the analyses.”
With more time, these and other key issues can be addressed by the HECO Companies,
Independent Entity, Consumer Advocate, and AG. We request that the Commission reconsider
its prior communication indicating that no extension may be granted.
We appreciate the Commission’s dedication to an open and effective IRP process to date, and we
thank the Commission in advance for considering this request for extension.
Respectfully submitted as members of the IRP AG,
Bash Nola, Blue Planet Foundation
Isaac Moriwake, Earthjustice
Leslie Cole-Brooks, Hawaii Solar Energy Association
Greg Kahn, I Aloha Molokai
Betsy Cole, The Kohala Center
Henry Curtis, Life of the Land
Kyle Datta, Ulupono Initiative
Jennifer Chirico, University of Hawai‘i, Maui College
Warren Bollmeier
Dick Mayer
cc: HECO Companies
Independent Entity
Office of the Consumer Advocate
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2
See Framework at 3: “The Commission will review the utility's Scenarios, Resource Plans, Action Plan,
and evaluations, and generally monitor the utility's implementation of its Action Plan. Upon review, the
Commission shall approve, reject, approve in part or reject in part the Action Plan, or require
modifications of the utility's Scenarios, Resource Plans and Action Plan, as applicable.”