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Hū Honua thermal effects report must be revised to 36 MW based on AR PPA

Pg. 14 of the PUC's Docket 17-0122, Decision and Order, regarding Hu Honua and HELCO's amended and restated power purchase agreement (“AR PPA”) confirms that the new contract cost is based on an average dispatch of 200,000 KW hours [per year].  That would not include parasitic electricity used to run the power plant. Hu Honua confirmed “the A&R PPA's pricing results in an estimated all-in levelized cost of $0.221/kWh, assuming a dispatch of 200,000 MWh, which Hu Honua believes is appropriate given that the reduction to the energy price will make Hu Honua more competitive with other system resources.  D&O at Pg. 11.  That means that Hu Honua would have to operate at 30 MW net/36 gross for more than 14 hours a day to produce 200,000 MWH a year. 

The AR PPA is absolute proof that Hu Honua has the intention to run the power plant at maximum 36 MW loads most of the time.  Hu Honua cannot now argue in the CWB review of the UIC operating permit for compliance with the clean water act and Hawaii’s water quality laws and rules, that the thermal effects report will reflect the AR PPA when modeled for lower loads of 25 MW gross.

HAR Chapters 11-54 and 11-55 uses maximum daily temperature limits.  Hu Honua’s thermal effects report does not make a showing of a measurement of conformance with water quality laws and rules unless it is modeled on 36MW loads 24/7. 

- Claudia Rohr

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