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Saturday, February 29, 2020

Hu Honua Update

Hawai`i Public Utilities Commission

“Each person has the right to a clean and healthful environment.” The clause was proposed by the Hawai`i Constitutional Convention of 1978 and approved by the voters in November 1978. It is now Article XI Section 9 of the State Constitution.

The Constitutional Convention committees did not mention climate change. That issue rose to prominence as the Kyoto Protocol was being debated in the late 1990s.

The Hawai`i Supreme Court upheld Life of the Land`s appeal of the Public Utilities Commission approval of the Hawai`i Electric Light Company (HELCO) Power Purchase Agreement (PPA) with Hu Honua BioEnergy LLC in May 2019.

The high court held that Life of the Land had a constitutional right to a “clean and healthful environment” and the Public Utilities Commission has a legal obligation to examine climate change.

Hawai`i Revised Statutes (HRS) §269-6  defined the Commission`s general powers and duties.

“The commission shall explicitly consider, quantitatively or qualitatively, the effect of the State's reliance on fossil fuels on price volatility, export of funds for fuel imports, fuel supply reliability risk, and greenhouse gas emissions. 

"The commission may determine that short-term costs or direct costs that are higher than alternatives relying more heavily on fossil fuels are reasonable, considering the impacts resulting from the use of fossil fuels.” (HRS §269-6)

The Commission re-opened the HELCO-Hu Honua Power Purchase Agreement proceeding to consider all aspects of the proposed contract including greenhouse gases.

“Given the interconnectedness of the issues in this docket, including new Issue No. 4 [greenhouse gases], established by this Order, the commission finds that for this specific docket, it would be beneficial for all Parties and Participants to address all issues set forth for this docket.”

An unresolved issue is what can or must be considered.

Hu Honua wants to burn wood chips. Burning wood has higher emissions than burning fossil fuel.

The Department of Health regulates all emissions including toxics and greenhouse gases.

The Public Utilities Commission evaluates projects based on their relative impacts.
The Public Utilities Commission has a 30-year history of sporadically considering non-greenhouse gas environmental impacts of utility projects, and to a lesser extent,  greenhouse gas impacts of utility projects.

Are all emissions or only greenhouse gas emissions on the table? The parties and participants in the proceeding disagree.

The Public Utilities Commission must write a thorough decision and order that addresses this issue. The losing side may appeal the proceeding back to the Hawai`i Supreme Court.

This is just one of several contentious issues that the Public Utilities Commission will be included in its decision.

The second issue addresses agriculture and farming.

The 2009 state legislature wrote a very small and confusing bill which became HRS §269-27.3.

“Preferential renewable energy rates; agricultural activities. 

“It is the policy of the State to promote the long-term viability of agriculture by establishing mechanisms that provide for preferential rates for the purchase of renewable energy produced in conjunction with agricultural activities. 

“The public utilities commission shall have the authority to establish preferential rates for the purchase of renewable energy produced in conjunction with agricultural activities.
“Upon receipt of a bona fide request for preferential rates for the purchase of renewable energy produced in conjunction with agricultural activities, and proof that the renewable energy is produced in conjunction with agricultural activities, a public utility shall forward the request for preferential rates to the public utilities commission for approval.”

The first request to use this section was for the highly contentious and ultimately failed Anaergia proposal for West Maui. Hu Honua filed the second request.

This law was written so that farmers could have a second revenue stream: crops plus energy sales. The added revenue would go to farmers.

Hu Honua wants it to be applied to their operations.

Hu Honua is part of a complex structure of inter-related companies that Hu Honua has refused to discuss in the Public Utilities Commission proceeding.

Two entities signed contracts to lease forests from Parker Ranch and Kamehameha School. One of those two entities will do all the chopping of trees and the re-planting of trees. That entity will then sell wood to Hu Honua.

Is Hu Honua an agricultural company?

If you buy a Christmas tree from a local store, which in turn requires someone to plant another tree for another future sale, are you a farmer?

Or is Hu Honua engaged in an agricultural activity because some entity related to them is engaged in an agricultural activity?

The documents are hidden behind a wall of confidentiality. Life of the Land has been allowed to review some of them.

Tawhiri, owner of the South Point Wind Farm is a participant in the proceeding but not privy to these documents.

Are all emissions, or only greenhouse gas emissions, that can be assessed in this proceeding?

Both emissions are regulated by the Department of Health.  

The Public Utilities Commission must figure out a way to address the issue. The losing side may appeal the proceeding back to the Hawai`i Supreme Court.

The third issue is what to compare the Hu Honua project to renewable energy facilities or fossil fuel generators?

The Consumer Advocate and Life of the Land note that recent solar plus battery contracts are far cheaper than Hu Honua.

Hu Honua asserts that it produces power 24/7 which renewable can`t do.

But is that relevant anymore? Can storage provide power on demand? Can the rate be designed to encourage customers to use solar and wind energy when they are available? These issues are being delved into in open dockets before the Public Utilities Commission.

Still another issue is the Waiver from Competitive Bidding. The Hu Honua project was given an exemption in 2008.

Should it continues to have effect? The Commission may have never rescinded a Waiver before but has asked parties to address the issue.

A new issue was recently raised by Hu Honua. Because Parker Ranch and Kamehameha School planted trees with the intent to harvest them, they pre-sequestered the carbon that will now be released by burning them.

Hu Honua is not causing climate change, it is merely returning carbon to the atmosphere that was originally in the atmosphere.

The Hu Honua plant is 95% complete. Hu Honua believes that as long as they are able to slowly finish the rest of the construction, and end it just as the final approval is locked in place, they may be able to get a $150 million federal Investment Tax Credit.

Jonathan M. Jacobs, a Hu Honua witness, filed testimony with the Public Utilities Commission in January 2020. Regarding completion of the Hu Honua BioEnergy (HHB) facility.

The completion of the HHB plant has been delayed but I have been told it is anticipated to be completed during the summer of 2020.”

“It would be very difficult for a wind or solar resource to do so, and it is very unlikely that any firm dispatchable renewable resource could be in place by Hu Honua planned online date later in 2020.”

“We understand that Hu Honua is planning to begin operation in mid-2020.”

HECO, MECO, and HELCO are currently reviewing 75 proposals for renewable energy, energy storage, of other  options for O`ahu, Maui, and Hawai`i Island.

The Public Utilities Commission must determine whether the Hu Honua proposal is reasonable and in the public interest.

Apr 8
Hu Honua BioEnergy LLC registered with DCCA
July 16
Hu Honua Waiver from Competitive Bidding
(docket no. 2008-0143)
Nov 14
Decision and Order
Aug 30
Power Purchase Agreement
(docket no. 2012-0212)
Dec 20
Decision and Order No. 34726
May 9
Amended and Restated Power Purchase Agreement
(docket no. 2017-0122)
July 28
Decision and Order No. 34726
Aug 28
Life of the Land Appeals Decision
May 10
Hawai`i Supreme Court upholds Appeal
June 20
PUC Docket Reopened
Feb 28
Final Information Requests
Mar 6
Responses to Final Information Requests
Prehearing Statements of Position
Prehearing Conference
Evidentiary Hearing
Transcripts Filed
3 weeks later
Post Hearing Briefs

Decision & Order

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Monday, September 9, 2019

Hawai`i Climate Change Litigation Needs Your Support

              We hope that this finds you well. The Board of Directors and Kat and myself want you to know how grateful we are for your support of Life of the Land’s work to protect all that make the Hawaiian Islands one of the most special places on the planet. Mahalo for being a beacon of hope in these times when we are witness to the preventable devastation of the Amazon and the rapid dismantling of environmental protection laws.

              We write today to humbly ask for your support specifically since Life of the Land represents the community in the first two climate change litigation proceedings in Hawai`i.

The first major climate change action that LOL is involved in is the Hu Honua project in Pepe`ekeo that proposes to raze forests to burn wood in order to produce electricity. The Amazon is being set on fire, What don’t they get?  

Bill McKibben said, “"Of all the solutions to climate change, ones that involve trees make people the happiest. Earlier this year, when a Swiss study announced that planting 1.2 trillion trees might cancel out a decade’s worth of carbon emissions, people swooned [] So it may surprise you to learn that, at the moment, the main way in which the world employs trees to fight climate change is by cutting them down and burning them."

              The community on the Hamakua Coast is actively against the project that has been secretive and dismissive of their concerns. 

Life of the Land intervened, however, the Public Utilities Commission (PUC) approved the sale of Hu Honua electricity to HELCO anyway. LOL then appealed the PUC decision to the Hawai`i Supreme Court. The Court upheld Life of the Land’s appeal and is forcing the PUC to hold a contested case proceeding (evidence, testimony, and an evidentiary hearing). We are facing HELCO and Hu Honua and their battery of attorneys.  Only Life of the Land can present the community`s perspective in this proceeding.

Aware that climate change was becoming an issue, the PUC allowed us into the Gas Company Rate Case solely to discuss climate change. The PUC then ignored climate change completely in their decision in this case, so we appealed to the Hawai`i Supreme Court in January 2019. The Gas Company filed their Answering Brief of July 31, and the PUC filed their answering brief on August 30. LOL will file a Reply Brief. We are represented by two terrific attorneys, Lance Collins and Bianca Isaki.

              This is why Life of the Land is humbly asking you to make a tax-deductible donation … so that we have the resources to present a strong, evidence-based case against corporate interests who care little for our people. Your support has kept Life of the Land alive for 50 years. We are your voice in these David and Goliath struggles…and we are winning! Please send your support today!
Mahalo nui!
Henry Curtis
Executive Director
LOL, P.O. Box 37158, Honolulu, HI 96837

People of conscience need to break their ties with corporations
financing the injustice of climate change.
Desmond Tutu

Friday, September 6, 2019

Life of the Land -- Status of Two Climate Legal Actions

Posted on September 6, 2019

Hu Honua Bioenergy proposed chopping down and burning forests to generate electricity in 2008.

Life of the Land, founded in February 1970, has been in 50 Hawai`i Public Utilities Commission regulatory proceedings including 10 dealing with BioEnergy.

The Hawai`i Public Utilities Commission twice approved the Hu Honua – Hawai`i Electric Light Company (HELCO) contract.

The Hawai`i Supreme Court upheld Life of the Land`s appeal remanding the case back to the Commission. 

The court ruled that Life of the Land has a constitutional right to a “clean and healthy environment," and that the Commission has been mandated to examine greenhouse gases since 2011.

The Public Utilities Commission is in the initial stages of a greenhouse gas contested case proceeding. 

The parties are HELCO, Hu Honua, and the Consumer Advocate.

The participants are Life of the Land, Tawhiri, and Hamakua Energy.

The Commission is requiring Hu Honua to conduct a life cycle assessment including building the facility, acquiring the fuel, and burning the fuel.

Documents must be filed on September 17, 2019: (1) preliminary briefs by all parties and participants, and (2) a draft Procedural Schedule filed only by the parties.

A second Life of the Land appeal is before the Hawai`i Supreme Court. This deals with climate denier Hawai`i Gas.  

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Monday, December 11, 2017

Spoof: Hawai`i can cost-effectively use 100% renewable energy by 2020

Outdoor Coal Pile in Campbell Industrial Park, O`ahu

This spoof has two initial scientific statements.

(1) Einstein wrote e=mc2. The law of mass–energy equivalence states that anything having mass has an equivalent amount of energy and vice versa.

(2) The first law of thermodynamics, also known as Law of Conservation of Energy, states that energy can neither be created nor destroyed; energy can only be transferred or changed from one form to another.

QUESTIONIf energy cannot be created nor destroyed, what is renewable energy, and how can we achieve 100% renewable energy?

FACTS: Renewable energy is a politically defined term, a political football. Governments across the US have a 1000 different definitions.

Hawaii has several very different definitions of renewable energy since 2000. At one point just a few years ago, Hawai`i considered that energy demand displaced by energy efficiency devices was renewable energy.

Destroying third world rainforests to grow genetically engineered bioenergy crops for HECO, MECO & HELCO generators is considered by Hawai`i to be renewable energy. Ethanol is also defined to be renewable energy.

There is also the difference between law and practice. Coal isn`t defined as renewable energy, but it is counted as renewable if it is burned at Honolulu`s H-Power garbage-to-energy plant.

SPOOF SOLUTION 1: The simple, cost-effective way, of achieving 100% renewable energy in year X, is to pass a law redefining renewable energy to include all forms of energy in year X.

SPOOF SOLUTION 2: Convert all energy demand to gas provided by the Gas Company, and/or diesel burned in on-site generators. Both are exempt from all renewable energy requirements.  

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Saturday, August 26, 2017

Life of the Land Appeals Hu Honua Decision


Henry Curtis, Executive Director
Life of the Land
(808) 927-0709


HONOLULU – Monday, August 28, 2017 -  Life of the Land has lodged an appeal to the Hawai`i Supreme Court to reverse the Public Utilities Commission ruling in favor of the HELCO-Hu Honua biomass power purchase agreement. This is the first challenge by a PUC docket participant regarding climate change and greenhouse gas emissions in Hawai`i. Life of the Land is represented by Maui attorney Lance D. Collins.

          The PUC granted Life of the Land participant status in this case because of our extensive research and understanding of energy and environmental issues. “It is critical that state regulatory agencies consider climate change,” asserted Henry Curtis, Executive Director of Life of the Land. “And, the PUC is specifically required by law to do so.”

          Since 2011, the PUC has been expressly mandated by state law (Act 109 SLH 2011) to consider greenhouse gas emissions in their decision-making but has continued to totally disregard its duties under the law.

          Life of the Land believes that the total lack of any analysis let alone any mention of greenhouse gas emissions in the final decision of the Commission was grave error compounded by the PUC's categorical dismissal of Life of the Land's attempts to raise these issues. Life of the Land is asking that the Hawaii Supreme Court vacate the PUC's decision and direct it to properly consider all issues required by law.

          This failure is even more troubling in light of more recent enactment of Act 32 (SLH 2017): “The legislature finds that not only is climate change real, but it is the overriding challenge of the 21st century and one of the priority issues of the senate.  Climate change poses immediate and long-term threats to the State's economy, sustainability, security, and way of life.”

          Life of the Land is Hawai`iʻs own energy and environmental group working to protect the people and the `aina since 1970. Our mission is to preserve and protect the life of the land through research, education, advocacy, and when necessary, litigation.

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Life of the Land`s Statement of Position re Hu Honua

Life of the Land filed its Statement of Position with the Public Utilities Commission on July 10, 2017. This is a web-based version, excluding many footnotes, and formatting it in a web-friendly version.

This proceeding involves a Hawai'i Electric Light Company (HELCO) proposed Power Purchase Agreement (PPA) with Hu Honua Bioenergy LLC which was filed with the Hawai'i Public Utilities Commission. After reviewing the filings in this proceeding. Life of the Land (LOL) believes this project is not in the public interest and should be rejected

I. Hu Honua’s Proposal Fails to Fully Address Issues of Climate Change and the Environmental Impact of their Proposed Operations.

The first two sentences of SB559 SD1 HD2 CD1, which Governor Ige signed into law as Act 32, read: “The legislature finds that not only is climate change real, but it is the overriding challenge of the 21st century and one of the priority issues of the senate. Climate change poses immediate and long-term threats to the State’s economy, sustainability, security, and way of life.”

Notwithstanding this clear statement of State policy, Hu Honua 1) declined to discuss the environmental impact of its operations, 2) made unsupported “carbon” claims, or 3) simply refused to answer Information Requests on the subject.

Hawaiian Electric Industries CEO Constance Lau spoke at the VERGE Hawai'i 2017 conference. (Lau`s comment started at about 41 minutes 57 seconds).

“Everybody is still moving in the same directions, that they were moving in, and particularly for the electric utility industry, that's been towards much more renewables, and it all started with climate change, and it's still is about climate change, but frankly, there are so many forces that are actually making it economically right, to have renewables.”

When community members asked the Hu Honua team about their statements on climate change at a community meeting in Kukuihaele Village, on June 19, 2017, one member, Rob Robinson told the community, “We are carbon-neutral.” Another team member, Kevin “KJ” Johnson qualified this to, “In our ends up being carbon neutral.” No details were offered aside from an assertion that they would plant trees that would be harvested and replanted every seven (7) years. No discussion of the carbon costs of transportation or the harvesting operation itself was discussed.

When LOL subsequently submitted Information Requests on June 29, 2017, including whether, “In Hu Honua's view, is Climate Change a public interest issue?” and “In Hu Honua's view, is avoiding greenhouse gas emissions a public interest issue?”, Hu Honua responded on July 7, 2017 that it objected to each request: “It is not relevant or material to Issues Nos. 2.a.i or 2.b, which are the only issues for which the Commission authorized LOL's participation.”

In reality, the issue of climate change is embedded in both issues the Commission assigned to LOL to consider:

Issue 2(a)(1): ''Whether the energy price components in the Amended and Restated PPA properly reflect the cost of biomass fuel supply.” According to HECO's Project Economic and Bill Impact Analysis, the benefits of the project include reductions in emissions and increases in energy security, but “the benefits from these other factors have not been explicitly quantified or monetized in the calculation of the Project’s benefit-to-cost (B/C) ratios but nonetheless are important considerations in the determination of the overall viability of the project.” The cost of biofuel includes both financial and non-financial components, which Hu Honua has failed to adequately address.

Issue 2(b): “Whether HELCO's purchase power arrangements under the Amended and Restated PPA are prudent and in the public interest.” The issue of climate change is of major public interest to the State and to the world, except, apparently, to Hu Honua.

Contrary to Hu Honua’s contentions, it is beyond doubt that LOL can, and has, raised climate change issues and greenhouse gas emission issues in previous Commission proceedings. In fact, this proceeding before the Commission is the ninth regulatory action dealing with Hawaiian Electric Companies bioenergy applications in which LOL is the only party or participant that represents environmental and community interests.

When HECO filed an application for the Campbell Industrial Park Combustion Turbine 1 with the Commission, Docket No. 2005-0145, LOL was a party, and was permitted to cross-examine a number of HECO witnesses on climate change. Several HECO witnesses testified to the effect that “Aren’t there two sides to this question?” and “It’s not my kuleana,” and “I`m not really up on this issue.” However, one of HECO’s witnesses, Senior Vice President for Public Affairs for Hawaiian Electric Company, Robbie Aim, conceded as follows:

“You know, Hawaiian Electric does not have the resources to conduct independent science, scientific research on the issues related to global warming. But like you, we've seen the growing body of scientific evidence which tells us the following: That human activity has caused an increase in global warming, that the human activity which has the strongest impact on this increase is the burning of fossil fuel, and that global warming has associated climate change impacts. We accept — you know, even though we cannot independently, scientifically verify that, we accept this as an operating premise for our actions and we accept our need to be part of the solution.”

Also in that Docket, LOL sponsored one of the world's pre-eminent scientists questioning the role of biofuels. Dr. Tad Patzek’’ has been a consultant and expert witness for the California Energy Commission, General Electric, Inc., and has testified before Congress. In testimony before the Commission, Dr. Patzek had this to say:

"People, especially the so-called pure environmentalists, are loath to accept the fact that what they think religiously -- that is, green is good — is not necessarily so. And they really have a hard time believing or accepting or- thinking that not everything that is green is in fact good."

“One must calculate the C02 emissions over the life cycle of the Corn-Ethanol System. Emissions of other gases, mostly nitrous oxide N20, ammonia NH3, and methane CH4, must be converted to equivalent C02 emissions using their relative potencies in creating the greenhouse effect. The methodology for determining equivalent C02 emissions must include all emission sources.”

For ethanol production, Patzek listed in descending order, the equivalent C02 emissions from 18 different aspects of production, use, and disposal. The top three were (1) use in a power plant, (2) Humus Oxidation of the soil, and (3) Nitrogen as Ammonia Fertilizer. The fifth element to be considered was transportation, which Hu Honua ignores.

Cognizant of the fact that the number of bat takings is a central issue in the pending Habitat Conservation Plan (HCP) for the Na Pua Makani wind generation facility in Kahuku, LOT also asked Hu Honua questions about potential impacts to endangered and threatened species. Despite Hawaiian Electric Industries CEO Constance Lau’s comments to the VERGE Hawai'i 2017 conference, that the community must have a voice to express concerns such as bird kills, “They are all really important issues that must be on the table.” Hu Honua refused to respond to LOL’s questions regarding whether bats or other endangered species would be impacted by proposed logging operations, stating it is beyond the scope of LOL’s participation in this docket.

To summarize: Hu Honua plans to chop down existing trees for seven years, and then to rely on a rotational system of growing new trees and then chopping them down. Omitting any discussion of the fossil fuels used in the mechanization of growing, chopping, chipping, and transport, Hu Honua alleges that this operation is carbon neutral. In the absence of hard facts, however, the only thing supporting Hu Honua’s analysis is an audacious statement that amounts to, “Trust us, we're green.”

Hu Honua also plans to supplement tree harvesting with other not clearly identified biomass supplies. Again, these are assertions of carbon neutrality without supporting facts or analysis. Hu Honua’s attempts to avoid meaningfully addressing climate change and the environmental impacts of their proposed operations with absurd statements such as “the Commission will not allow LOL to ask questions relevant to these issues”, speaks volumes.

II, The Pricing of Hu Honua's Proposal is not in the Public Interest and its Economic Analysis is Incomplete.

In the face of dramatically falling prices across the globe, Hu Honua has proposed a 30- year contract, running from 2019 to 2048. Hu Honua is asking to be paid over 20 cents per kilowatt-hour in 2018, which would then rise to over 32 cents per kilowatt-hour in 2048. Unidentified additional costs to cover transmission, distribution, and administration will then be tacked on by HELCO.

Compare the above with the following examples of lower priced proposals: the Hawai'i Public Utilities Commission approved the KIUC-AES Lawai Solar, LLC Power Purchase Agreement for solar-based electricity, at 11.08 cents per kWh, in Docket No. 2017- 0018, and approved the KIUC-SolarCity Corporation solar-plus-battery Power Purchase Agreement at 14.5 cents per kWh. 

The Commission also approved a waiver from competitive bidding for the proposed West Loch PV Project, stating, “the Equivalent Levelized Energy Payment for the Project, as well as the PPA equivalent energy price, is estimated by HECO and the Consumer Advocate to be 9.56 cents per kilowatt-hour (kWh).” 

With respect to the West Lock Project, the Commission took notice of Tucson Electric Power's solar-plus storage project priced at 4.5 cents per kWh.

Moreover, Hu Honua's cost analysis included “Comparing HELCO Fossil Fuel Units to Hu Honua Bioenergy” whereby they asserted Hu Honua’s operations would save Big Island ratepayers some $600,000,000.00 starting in 2040. These numbers, however, are based on the high cost of biomass relative to the higher cost of fossil fuel, despite the fact that HELCO has asserted it will not be selling fossil-fuel-based electricity by the 2040s. When LOL questioned Hu Honua on these issues, Hu Honua refused to answer, stating that it was beyond the scope of what LOL was permitted to address in this proceeding.

The question for Big Island ratepayers and for the Commission is: why should a 30-year contract lock in high prices in the middle of a turbulent transformational period in which the price of firm baseload solar plus storage is sharply decreasing, and the power and duration of storage is rapidly increasing?

In addition to the dramatic and continuing downward trend in the cost of electricity generated by solar and solar-plus-battery systems, there are other advances being made which will fundamentally alter the reality of today. 

The Commission has an open proceeding on Demand Response, whereby utilities can rely on customer-based energy efficiency, renewable energy, and energy storage systems, to displace the need for centralized firm power, while saving money for all ratepayers. The “demand response” approach is poised to change everything. Hawai'i is at the leading edge of a vast energy-based technological revolution. What will the cost and environmental impact trajectories look like in the second and third decade of Hu Honua’s fixed-price, cost-escalating proposal?

An additional weakness in Hu Honua’s proposal is its analysis of economic benefits. Hu Honua stated that one economic benefit of the high-cost electricity they propose to provide would be job-creation: “Hu Honua operations are projected to generate about 190 jobs on the Big Island, including approximately 30 jobs at the power plant, 70 forest jobs, 20 trucking jobs, and 70 indirect jobs. ... Earnings from these jobs are expected to support 430 residents living in about 190 homes.” 

When LOL asked a series of questions concerning Hu Honua’s job creation claims, including an analysis of the number of people employed in different potential energy futures, like biomass relative to solar plus battery, Hu Honua responded that it was none of our business and beyond the scope of what LOL was permitted to address in this proceeding. 

Hu Honua then suggested that IF it decided to do something in the future (but to which it was not committing, merely speculating that they are capable of doing), then the Big Island will obtain additional benefits. “If Hu Honua uses Albizia trees”, Hu Honua opines, this “would have a value to the community.” This “value” was not defined by when it would potentially be implemented nor was it quantified.

Hu Honua’s pricing is not reasonable nor in the public interest and its economic benefit analysis is incomplete

III. Conclusion

Hu Honua’s offer of pricing is unreasonable and not in the public interest. In light of steadily-decreasing costs for other energy sources, Hu Honua’s costs are exorbitant and escalating. Even if the proposed pricing could be somehow deemed reasonable, Hu Honua’s environmental-impact discussion is incomplete and its claim of “carbon-neutrality” is unsupported. Furthermore, Hu Honua's approach is in violation of the Hawai'i Revised Statutes, §5-7.5, the Aloha Spirit, and displays a disturbing disregard for community concerns. The Commission should reject Hu Honua’s proposal.

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