Implementation of Executive Order No. 25-01
Public Utilities Commission
Implementation of Executive Order No. 25-01
On January 25, 2025, Josh Green, M.D., Governor of the State of Hawaii, signed Executive Order No. 25-01 (“Executive Order”), calling for “collective actions to accelerate the State’s decarbonization, stabilize and reduce energy costs, lower the State’s carbon footprint, fortify energy security, and gain access to capital for the energy transition….” Specifically, as to the Public Utilities Commission (“Commission” or “PUC”), the Executive Order urges the PUC in Section 4 to:
- Provide direct bill savings and other benefits to communities that host large-scale energy generation, prioritizing bill savings for low- and moderate-income households and those living on Hawaiian Home Lands;
- Maximize the use of distributed clean, renewable energy resources across the state to improve resilience and energy security, with a particular focus on maximizing DERs in Public Safety Power Shutoff areas, as well as on every rooftop and as canopies over parking lots and shared spaces on land-constrained Oʻahu;
- Eliminate redundancies and inefficiencies in interconnecting independent power producers to the grid, enabling the safe and rapid addition of modern renewable energy generation into the grid, including but not limited to implementing appropriate rules for the creation of Renewable Energy Zones.
- Investigate how battery storage can be added to older distributed solar systems to increase their ability to dispatch renewable energy;
- Expand energy service markets, streamline procurement of decarbonized energy resources, and create a grid that enables distributed resources to provide grid services with appropriate compensation for the benefits they provide to the grid;
- Develop a timeline for the Hawaiian Electric Company to demonstrate reduced energy generation costs, harden vulnerable distribution infrastructure, and outline a path to financial stability for the company;
- Develop and publish a timeline for acting on the priorities listed above within 60 days.
In response to the Executive Order, the PUC affirms its commitment to accelerating Hawaii’s transition to renewable energy. The Commission recognizes the critical importance of the energy transition to achieving the State’s decarbonization goals, while concurrently striving to make improvements in energy access, affordability, and overall resilience across the energy system.
As part of the State’s broader efforts to accelerate the renewable transition and to enhance resilience against natural hazards, the Commission seeks to:
- Timely review and approve requests for prudently incurred utility investments in renewable energy and storage, make-ready infrastructure for electric vehicle charging, and infrastructure to improve resilience.
- Maintain a robust performance-based regulatory framework that works to:
- Manage prudent costs and support progress on key policy goals, such as the 2045 Renewable Portfolio Standard (“RPS”).
- Accelerate the deployment of cost-effective distributed energy resources (“DER”).
- Continue reductions in greenhouse gas (“GHG”) emissions.
- Reduce exposure to oil market volatility.
- Enhance resilience against natural hazards.
- Improve utility operational efficiency and reduce costs.
- Minimize rate impacts, such as through the following:
- Continued development and support of energy efficiency programs that reduce electricity demand, lower customer bills, reduce greenhouse gas emissions, and deliver savings to disadvantaged communities, particularly through leveraging the Hawaii Energy residential, business, and community-based energy efficiency programming.
- Design DER incentives to accelerate DER adoption, especially in disadvantaged and wildfire-prone communities, while mitigating cost shifts to non-participating customers.
- Ensure utility resilience investments are coordinated and focused on the highest-risk geographic areas and most vulnerable infrastructure.
- Examine opportunities to reduce upfront costs and improve affordability.
- Coordinate efforts with State agencies on policy development, funding, public utility engagement, and processes, including permitting, procurement, and energy efficiency standards.
- Establish and enforce standards and guidelines for public utilities, including benchmarks for resilient infrastructure improvements and performance and DER integration.
As to the specific areas of focus assigned to the Commission in the Executive Order, Table 1 provides a timeline of docket proceedings and other initiatives relevant thereto. Table 2 categorizes the information by specific area of focus. While there are many aspects to advancing the State’s energy transition and the priorities within the Executive Order, the Commission emphasizes, in particular, the following initiatives:
1. Power Purchase Agreement (“PPA”) Applications for Renewable Energy Generation
The Executive Order urges the Commission in Section 4b. to “maximize the use of clean, renewable energy” resources, in Section 4c. to “[e]liminate redundancies and inefficiencies in interconnecting independent power producers to the grid”, and in Section 4e to “[s]treamline procurement of decarbonized energy resources”. Through 2030, the Commission expects the Hawaiian Electric Companies (“HECO”) and Kauai Island Utility Cooperative (“KIUC”) to file several applications for PPAs for over 500 megawatts (“MW”) of firm generation and over 2,400 MW of Hybrid Solar + Wind + Battery Energy Storage Systems (“BESS”). From 2030 to 2050, the PUC expects electricity utilities to file several applications for PPAs for over 4,500 MW of Hybrid Solar + Wind + BESS, 400 MW of Offshore Wind, and 30 MW of Geothermal. Each PPA application will have a new dedicated docket proceeding. During this time, HECO and KIUC plan to retire or deactivate over 1100 MW of fossil fuel generation. The Commission staff must carefully evaluate each PPA to ensure accountability and alignment with policy goals. Key aspects of the evaluation include assessment of:
- The financial fitness of the developers;
- Expected energy output and its impacts on the reliability of the electric system;
- Pricing and costs (e.g., bill impacts for consumers, any cost-sharing agreements, and subsidies involved);
- Contract terms and conditions (e.g., contract length, force majeure provisions);
- Project location and impact (e.g., easement considerations, proximity to grid interconnection points, environmental and community impacts of the project)
- Operations and performance metrics;
- Expected greenhouse gas (GHG) emissions;
- Community and Economic Benefits (e.g., community benefits packages, investments in local infrastructure or programs, job creation and workforce development commitments, efforts to address host community concerns);
- Alignment with State energy policy goals (e.g., renewable portfolio standards);
- Commitment to ethical and transparent negotiations;
- Disposal and recycling of waste and materials that have reached end of life; and
- Relationship to other federal, state, and county permitting and regulatory processes.
2. Distributed Energy Resources (DER) and Grid Services Policies and Programs
The Executive Order urges the Commission in Section 4b. to “[m]aximize the use of distributed clean, renewable energy resources across the state to improve resilience and energy security, with a particular focus on maximizing DERs in Public Safety Power Shutoff areas, as well as on every rooftop and as canopies over parking lots and shared spaces on land-constrained Oʻahu”. DERs are small-scale resources that enable customer participation in the generation and delivery of electricity service. The most common DERs used for electricity generation are rooftop solar photovoltaic panels, which are often paired with battery energy storage systems. Other types of distributed grid resources include water heaters and air conditioners. The Commission oversees the design and implementation of DER programs in Docket No. 2019-0323 and grid services in several docket proceedings. PUC will be opening a new investigative docket in 2025 to develop more advanced DER and grid services programs. The PUC expects 400 MWs of new DER to be installed by 2030 under the Smart DER Program and new grid service programs.
On December 31, 2024, the Commission issued Order No. 41445, initiating DER Program Structure (“DPS”) Phase 4, in which the Commission ordered the Parties to investigate the ConnectedSolutions program administered by the investor-owned energy company National Grid. The Massachusetts ConnectedSolutions program, in which participants make their DER batteries available for on-demand dispatch to serve peak load for up to 60 days per year, appears to have achieved a balance between attracting participants and providing valuable services to the grid at a reasonable cost. The Commission is interested in exploring whether all or portions of the ConnectedSolutions program could be adapted to work in Hawaii. This new grid service program would target LMI (low and moderate income) customers, customers with existing PV solar systems (there are over 600 MW of existing DERs that do not have BESS), and new DER customers.
On March 21, 2025, the Commission issued Decision and Order No. 41616, establishing the new Bring Your Own Device Plus program (“BYOD+”). BYOD+ aims to incentivize adoption of distributed battery systems by customers with existing and new rooftop solar. Half of the new BYOD+ Program’s capacity is reserved for LMI households with an annual income of less than 140 percent of the Area Median Income. LMI customers can receive an additional $400/kW upfront incentive with no cap. Future DER Program development will also consider designing cost-effective and equitable programs targeted in Public Safety Power Shutoff (“PSPS”) areas and to promote resilience during natural disasters.
3. Integrated Grid Planning (IGP)
The Executive Order urges the Commission in Section 4c. to “[e]liminate redundancies and inefficiencies in interconnecting independent power producers to the grid, enabling the safe and rapid addition of modern renewable energy generation into the grid, including but not limited to implementing appropriate rules for the creation of Renewable Energy Zones.” In 2018, the Commission opened the integrated grid planning docket proceeding, which was the first time that electricity generation, transmission, and distribution planning were combined. The PUC directed HECO to use better tools for modeling distributed generation to inform and improve both system-wide and distribution-level planning and operations. The IGP process aims to optimize how different energy, storage, distribution, and transmission resources will be added to utility systems. This approach could lead to significant customer savings and emissions reductions by considering both distributed and grid-scale resources together. The PUC accepted HECO’s IGP in 2024. A new IGP investigative proceeding will be launched in 2025. The Commission has directed the HECO Companies to establish Renewable Energy Zones in the first round of IGP, which will continue to be refined in the next iteration of IGP.
Competitive procurements for new utility-scale generation and grid services are informed by IGP results and overseen by the PUC, an Independent Observer, and Independent Engineer. Every five years, the HECO Companies develop a new IGP which is reviewed by the PUC and other stakeholders.
Resilience planning is a crucial part of IGP to ensure that power systems can withstand and recover from disruptions, such as natural disasters, cyberattacks, or equipment failures. The PUC has and will continue to work closely with HECO and stakeholders to incorporate resilience scenarios into IGP models to evaluate how different resource mixes perform under stress conditions, such as prolonged outages from natural disasters. Grid resilience, flexibility, and reliability can be enhanced with distributed generation and a balanced mix of utility-scale renewable energy and storage sited outside of disaster-prone regions.
4. Community Based Renewable Energy (CBRE)
The Executive Order urges the Commission in Section 4a. to “[p]rovide direct bill savings and other benefits to communities that host large-scale energy generation, prioritizing bill savings for low- and moderate-income households” and in Section 4e. to “[e]xpand energy service markets, streamline procurement of decarbonized energy resources, and create a grid that enables distributed resources to provide grid services with appropriate compensation for the benefits they provide to the grid”. In June 2018, the Commission approved the HECO’s CBRE tariff and program, subject to certain modifications. The CBRE program allows utility customers who are unable to directly participate in renewable energy generation because of their location, building type, access to the electric utility grid, and other impediments to participate directly in off-site renewable energy projects through a bill credit arrangement.
- Phase 1 – commenced in June 2018, with a total of 8 MW across the service territories. Of the 8 MWs, approximately 6 MW was allocated to several projects. Currently, there are approximately 4 MW online, providing bill credits to the subscribers.
- Phase 2, Tranche 1 – commenced in April 2020, expanding the program from 8 MW capacity to at least 235 MW to dramatically expand access to the economic, environmental, and societal benefits of renewable energy. Phase 2 specifically addresses the needs of renters, shared building occupants, and low-to-moderate income earners. Several awarded projects are in the latter stages of PPA negotiations.
- Phase 2, Tranche 2 – as the CBRE program moves into Tranche 2, the Commission is considering several options and revisions to the current program to better incentivize increased participation by developers and LMI customers.
Timeline and Overview of the Most Relevant PUC Docket Proceedings for Implementation of the Executive Order
Table 1 includes a projected timeline of docket proceedings that are responsive to the Commission’s responsibilities within the Executive Order. This table illustrates how most dockets are inter-related and impact several categories. The color applied to each docket should be viewed as the area of primary impact, with the understanding that the work in the docket may also heavily impact other areas. Table 2 provides a different view, categorizing the same work according to each subsection (i.e., 4a-4f) of the Executive Order.
While the docket proceedings listed herein may be considered to be the most responsive to the Executive Order, the list should not be viewed as all-inclusive. The overall body of the Commission’s work, including ratemaking and rulemaking governing the daily activities of public utilities, is also consistent with the goals of the Executive Order by facilitating efficient utility practice before the Commission, as well as furthering the State’s renewable energy transition.
| Key Initiatives |
| Power Purchase Agreement (PPA) Applications for Renewable Energy Generation |
| Distributed Energy Resources (DER) and Grid Services (GS) Policies and Programs |
| Community-Based Renewable Energy Programs (CBRE) |
| Efforts Associated with Integrated Grid Planning (IGP), Grid Modernization, Resilience, PPAs, DER and GS, and CBRE |
| Table 1: Summary timeline of PUC actions that address subsections 4a-4f of EO No. 25-01 | |
|---|---|
| 2024 |
|
| 2025 |
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| 2026 |
|
| 2027 |
|
| 2028 |
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| 2029 |
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| 2030 |
|
| Table 2. Summary of dockets (by category) that address subsections 4a-4f of EO No. 25-01 | |
| Executive Order Request | Related Dockets |
| 4a. Provide direct bill savings and other benefits to communities that host large-scale energy generation, prioritizing bill savings for low-and moderate-income households and those living on Hawaiian Home Lands; |
|
| 4b. Maximize the use of distributed clean, renewable energy resources across the state to improve resilience and energy security, with a particular focus on maximizing DERs in Public Safety Power Shutoff areas, as well as on every rooftop and as canopies over parking lots and shared spaces on land-constrained Oʻahu; |
|
| 4c. Eliminate redundancies and inefficiencies in interconnecting independent power producers to the grid, enabling the safe and rapid addition of modern renewable energy generation into the grid, including but not limited to implementing appropriate rules for the creation of Renewable Energy Zones. |
|
| 4d. Investigate how battery storage can be added to older distributed solar systems to increase their ability to dispatch renewable energy; |
|
| 4e. Expand energy service markets, streamline procurement of decarbonized energy resources, and create a grid that enables distributed resources to provide grid services with appropriate compensation for the benefits they provide to the grid |
|
| 4f. Develop a timeline for the Hawaiian Electric Company to demonstrate reduced energy generation costs, harden vulnerable distribution infrastructure, and outline a path to financial stability for the company; |
|
Public filings related to the dockets can be accessed by typing the docket number (e.g., 2019-0323) on the Commission’s website, https://hpuc.my.site.com/cdms/s/search.
Updated 4/2025