2014-0135

The excerpts provided indicate several financial and timeline risks and concerns discussed in this docket:

Financial Risks and Concerns:
- The ability of small businesses to access financing is limited by traditional underwriting criteria, particularly the requirement for investment-grade ratings, which many small businesses lack. This restricts their eligibility for financing and hinders their access to funds for projects, creating uncertainty around the inclusion of small businesses and for-profit multi-family rental projects in underserved segments 1.
- There have been instances of expired commitments, such as a $5 million commitment for a consumer lease facility and a $4.6 million commitment for nonprofit solar PV installations, which became available again due to lack of uptake or other issues. This suggests challenges in deploying allocated funds efficiently and highlights a risk of underutilization of available capital 2.
- The need for more visibility and reporting on the use of funds, as recommended by the Consumer Advocate, indicates concerns about transparency and the adequacy of information on costs and benefits associated with program expansions (e.g., to electric vehicles and charging stations) 3.

Timeline Risks and Concerns:
- There have been missed deadlines and technical issues with the docket management system, such as the authority not receiving alerts for information requests, leading to delayed responses and the need for deadline extensions 4.
- The Pig (Permitted Interaction Group) recognized that although GEMS financing could facilitate community-based renewable energy (CBRE) projects for underserved ratepayers, no funds were allocated due to lack of Commission approval at the time, introducing uncertainty and potential delays in project initiation 5.
- The need for regular status conferences, quarterly reports, and additional information requests from the Commission reflects ongoing concerns about timely program oversight and the adequacy of responses to regulatory requirements 6, 7.

In summary, key risks include difficulties in fund deployment, access to financing for targeted groups, transparency and reporting concerns, administrative delays, and technical issues with regulatory processes.

Stakeholders in Hawaii PUC Docket No. 2014-0135 (Green Energy Market Securitization/GEMS program) include:

- Hawaii Green Infrastructure Authority (HGIA): The applicant and program administrator, proposing enhancements such as expanding GEMS financing for community-based renewable energy (CBRE) projects and other clean energy initiatives 1, 2.
- Division of Consumer Advocacy (Department of Commerce and Consumer Affairs): Reviews proposals, sometimes with reservations or requests for additional information, but has not objected to expanding the use of GEMS funds for new purposes such as EVs, EV charging stations, and purchase options in existing PPAs, provided certain conditions and reporting requirements are met 3.
- Ulupono Initiative: An intervenor in related dockets, has expressed strong support for HGIA's proposals to use GEMS financing for CBRE projects to increase participation for low- and moderate-income (LMI) customers and promote energy equity 1, 1.
- Ho'ahu Energy Cooperative Molokai: Supports HGIA’s request to provide GEMS financing for CBRE projects, emphasizing the program’s energy justice and equity goals 2.
- Blue Planet Foundation: Was an intervenor, but filed a motion to withdraw in 2024, stating most of its concerns had been addressed 4.
- Hawaiian Electric Companies (HECO, MECO): Participate in the implementation of CBRE and related programs, and are referenced as working with stakeholders including HGIA and Ulupono 1, 1.
- City and County of Honolulu Office of Climate Change, Sustainability, and Resiliency: Participates in energy equity convenings with HGIA and other stakeholders 5.
- Project developers/property owners: Eligible for HGIA loans for multi-family rentals, CBRE projects, etc. 6.

Positions on Proposals:
- HGIA: Proponent of expanding and adjusting the GEMS program to serve additional clean energy purposes (CBRE, EVs, etc.) 2, 1.
- Division of Consumer Advocacy: Generally not opposed but seeks more information and oversight, especially on costs, benefits, and reporting transparency 3.
- Ulupono Initiative and Ho'ahu Energy Cooperative Molokai: Supportive of HGIA’s efforts to use GEMS funds for CBRE projects and LMI participation 1, 2, 1.
- Blue Planet Foundation: Previously involved but withdrew after determining its concerns were addressed 4.

No excerpts indicate any stakeholder is outright opposed to the main recent proposals. The Division of Consumer Advocacy sometimes expresses reservations or requests additional data, but does not object to expansion proposals when conditions are met 3.

The excerpts identify several areas of growth in the Green Energy Market Securitization (GEMS) program under Hawaii Green Infrastructure Authority (HGIA), along with key considerations for each:

1. Expansion of Loan Fund Uses:
- Areas: Financing purchase options in existing power purchase agreements (PPAs), electric vehicles (EVs), and EV charging stations.
- Key Considerations: The Division of Consumer Advocacy noted the need for more information on the cost and benefits of these expansions and recommended enhanced quarterly reporting for greater transparency regarding fund use 1.

2. Community-Based Renewable Energy (CBRE):
- Area: Use of GEMS financing and on-bill repayment mechanisms to facilitate CBRE for underserved ratepayers.
- Key Considerations: Flexibility in fund allocation is advised to respond to future market needs. At the time, no specific allocation for CBRE had been set aside as commission approval was pending 2.

3. For-Profit Multi-Family Rental Projects and Small Businesses:
- Area: Potential inclusion as eligible underserved participants.
- Key Considerations: Small businesses often lack investment-grade ratings, limiting access to traditional financing. HGIA had not yet classified them as underserved but indicated that future filings might address their inclusion, contingent on establishing criteria for when and why these groups should be considered underserved 3.

4. Program Oversubscription:
- Area: Demand exceeding available loan capital.
- Key Considerations: HGIA noted the need to source additional loan capital to meet demand, and there was a temporary moratorium on new applications as of November 30, 2024. Plans to reopen applications and the prioritization of current application queues, including consideration of grid capacity needs using utility data, are under review 4.

Each identified area reflects both the ongoing evolution of the program’s scope and the emphasis on careful consideration of financial, operational, and equity impacts in decision-making.

Key events and submissions in this proceeding include:

- July 24, 2020: Board meeting held; quarterly report for period ending June 30, 2020, filed with the commission on July 31, 2020 1.
- October 26, 2020: The commission filed an information request regarding a transfer of $34,004,860.68 by HGIA 2.
- October 28, 2020: Board meeting held 2.
- January 30, 2023: Board meeting held; approved secretary’s certificate for USDA RESP loan and HGIA’s quarterly report for period ended December 31, 2022 3, 4.
- January 31, 2023: Quarterly report for period ended December 31, 2022 filed with the commission in docket no. 2014-0135 3, 4.
- March 10 & 20, 2023: Public comments filed supporting HGIA’s request to finance community solar projects 3, 5.
- March 31, 2023: Board meeting held; HGIA’s FY2024 annual plan approved and filed with the commission 3.
- August 12, 2022: Program Notification No. 15 filed, requesting seven changes to the GEMS program 6, 6.
- August 30–31, 2022: Commission established procedural schedule to review Program Notification No. 15; public comment filed in support 7, 6, 6.
- June 16, 2023: Order No. 39377 filed, approving in part, denying in part, and modifying in part the requests under Program Notification No. 15 5.
- September 25, 2023: $3,716,042 transferred to PUC account at Bank of Hawaii 5, 8.
- December 28, 2023: HGIA distributed its 2023 annual report to the governor and legislature 5.
- January 29–30, 2024: Board meeting held; quarterly report for period ended December 31, 2023 filed 5.
- April 30, 2024: Next quarterly report scheduled to be submitted covering activities from January 1 to March 31, 2024 5.

This timeline highlights regular quarterly and annual reporting, program modification submissions (notably PN15), related board meetings, and significant financial transactions throughout the proceeding.

Docket No. 2014-0135 concerns the Hawaii Green Infrastructure Authority's (HGIA) Green Energy Market Securitization (GEMS) Program and its related green infrastructure loan activities. The docket covers:

- Initial creation and approval of the green infrastructure loan program, including orders and procedural schedules for review and modification of program notifications (PNs), such as PN14 and PN15.
- Expansion of the program’s scope over time, including financing options for power purchase agreements, electric vehicles and charging stations, and community-based renewable energy (CBRE) projects 1, 2.
- Ongoing regulatory oversight, including regular quarterly and annual reports by HGIA, financial audits, and responses to information requests from the Public Utilities Commission (PUC) and the Division of Consumer Advocacy 3, 4.
- Public and party participation through technical conferences, submission of information requests, statements of position, and public comments 5, 6, 7.
- Recent developments include a temporary moratorium on new GEMS applications as of November 30, 2024, due to oversubscription, with plans to source additional loan capital and consider reopening applications 8.
- The docket also addresses program enhancements, eligibility criteria (such as the inclusion of small businesses and multi-family rentals), and detailed tracking of fund allocation by borrower segment 9, 4.

In summary, the docket manages the approval, modification, reporting, and oversight of Hawaii's state-backed green infrastructure loan program, ensuring transparency, consumer advocacy, and alignment with state energy goals.