Tuesday, February 9, 2016

Should NextEra Gold Plate HECO's Grid?

By Henry Curtis

NextEra attorneys have been hammering away on reliability statistics. 

If only NextEra were to take over the HECO Companies then NextEra could bring its technical expertise to Hawaii to improve reliability in Hawaii.

Some have questioned the assumption that Florida Power & Light, with its flat as a pancake terrain, and Maui’s rugged terrain, could and should have equal reliability levels obtained at equal cost.

Some have noted that reliability can be thought of like a health plan, you can buy different plans according to your needs and your willingness to pay. This has become easier with the growth in on-site generation, on-site storage, and micro-grids.

HECO maintains one such distribution system in downtown Honolulu where customers pay a higher rate for having buildings connected to two different substations.

Campbell Industrial Park Substation, O`ahu. Photo by Author

Florida experienced the “Year of the Four Hurricanes” in 2004. For six weeks, Florida reeled under the assault of Hurricanes, Charley, Frances, Ivan and Jeanne.

The hurricanes were rated as Categories 4, 2, 3 and 3. In Florida they killed over 100 people and caused over $20 billion in damages.

 The following year Florida got whacked by Wilma, which until Patricia in 2015, was the most intense tropical cyclone recorded in the western hemisphere.

The damage was detailed in the Florida State’s Energy Emergency Response to the 2004 Hurricanes United States Department of Energy Office of Electricity Delivery and Energy Reliability issued by the National Association of State Energy Officials June 2005

As a result Florida Power & Light began a grid hardening program. This grid modernization made the grid more secure and increased reliability statistics.

The Florida approach but did not meet the grid modernization concept proposed by the Hawai`i Public Utilities Commission.

 The Hawai`i Public Utilities Commission envisions a grid able to interface with thousands of new rooftop solar systems in addition to the current 77,000 rooftop systems and the development of smart meters with time of use capabilities.

Waimea Substation, County of Hawai`i. Photo by Author

The relative level of reliability is influenced by the degree of transmission and distribution automation; the percentage of overhead versus underground delivery modes; relative grid network, loop, radial system configurations; customer density; urban versus rural wiring; coastal, mountainous and challenging terrain geographical impacts; and environmental factors such as vegetation, winds, rain, storms, and lightning strikes.

Virtually all outages occur on the distribution grid, but national attention often focuses on the few large transmission-level failures.  

The dated 20th century model is where residential loads subsidize commercial loads. Traditionally large commercial loads required higher reliability levels than residential loads. The total transmission grid is built to meet the higher reliability level.  The cost to upgrade the transmission grid is shared by all. However a single large commercial is easier to handle than several small loads, so commercial loads are given lower utility rates.

The Galvin Electricity Initiative, founded by Motorola chief Bob Galvin, noted a national problem which also occurs in Hawai`i. When a new development is built all ratepayers pay for new electrical upgrades.

An unintended consequence of subsidizing new development is less efficient, local, all-electric designs. When electricity distribution is provided for free, other more efficient design options cannot compete.

There are a number of significant challenges that would make this type of standardization very difficult and potentially lead to meaningless and unfair comparisons,” asserted the Edison Electric Institute (EEI).  

“There are a number of environmental and regional issues associated with standardization, such as differing customer demographics, geography, climate, and vegetation density. In addition, each utility has a slightly different system in terms of voltage, configuration, design, and redundancy, making it difficult to compare them only on the basis of reliability performance.”

The Department of Energy’s Lawrence Berkeley National Laboratory (LBL) is managed by the University of California. 

An LBL study from last year found “statistically significant correlations between the average number of power interruptions experienced annually by a customer and a number of explanatory variables including wind speed, precipitation, lightning strikes, and the number of customers per line mile.”

The study also found a “statistically significant correlations between the average total duration of power interruptions experienced annually by a customer and wind speed, precipitation, cooling degree‐days, the percentage share of underground transmission and distribution lines.”

 The Galvin Electricity Initiative asserted that “there is a perception among industry stakeholders that improved reliability requires higher rates. The cities of Naperville, Ill., and Chattanooga, Tenn., dispelled this myth by dramatically improving reliability without raising rates.”
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Monday, February 8, 2016

Legislature Considering New HECO Business Model

By Henry Curtis

One future electric utility model would have the electric utility become a middleman.

The utility would be a regulated transmission and distribution company which would buy power from independent third party producers and sells the energy to customers.

Introduced into the Hawai`i State Legislature this year, HB 2571 would divorce electric generation from electric delivery.

The bill, authored by Representatives Chris Lee, Scott Saiki and Nicole Lowen is being heard tomorrow by the Hawai`i House Committee on Energy & Environmental Protection at 8 a.m. in Conference Room 325.

“The legislature also finds that even in a period of significant energy transformation, Hawaii's vertically integrated and monopolistic investor-owned electric utilities have not transitioned, and do not appear to be transitioning, to a sustainable business model capable of addressing the ongoing energy transformation. 

Investor-owned electric utilities must transform over time from their current role as owner and operator of a fleet of generation units to that of ‘electric utility of the future’, which plays the critical role of system planner and operator of energy grids that are supplied with high levels of renewable and sustainable energy from distributed energy resources and independent power producers.”

“After December 31, 2020, investor-owned electric utilities shall not own or operate any generation resources in Hawaii, and investor-owned electric utilities shall not acquire electricity from any of their affiliated interests for distribution to their customers.”

This idea was proposed by Life of the Land twenty years ago in Public Utilities Commission docket number 1996-0493. Life of the Land suggested that HECO have a stock split whereby each shareholder would own shares in a generation company and shares in an independent transmission company.

A similar divorce occurred a decade ago in energy efficiency.

The Hawai`i Legislature sought to eliminate a perceived utility conflict of interest whereby a utility would make money selling electricity and yet received incentives to encourage customers to reduce their demand.

Act 162-2006 (SB 3185 SD2 HD2 CD1) authorized the commission to investigate an alternative business model.

“The public utilities commission, by order or rule, may redirect all or a portion of the funds collected through the current demand-side management surcharge by Hawaii's electric utilities into a public benefits fund that may be established by the public utilities commission.”

“If the public utilities commission establishes a public benefits fund, the public utilities commission shall appoint a fund administrator to operate and manage any programs established … The fund administrator shall be subject to regulation by the public utilities commission.”

The Commission opened docket 2005-0069.

The Consumer Advocate asserted, “The costs of implementing Energy Efficiency measures may be lower under a non-utility third-party administrator because recovery of lost margins would no longer be an issue and additional monies in the form of incentives may not be necessary.”

LIfe of the Land supported the Efficiency Vermont approach which created a “separate utility, a negawatt utility, solely for the purpose of energy conservation.” Life of the Land proposed that the “PUC issue a Request for Proposal (‘RFP’) to establish an efficiency utility to administer energy efficiency programs” and that “Load Management programs to stay with the utility.”

The Commission approved a “Non-Utility Market Structure” in its Decision and Order number 23258, dated February 13, 2007.

“All of the HECO Companies' Energy Efficiency DSM programs shall transition from the HECO Companies to the Non-Utility Market Structure, by January 2009, unless otherwise ordered by the commission. The HECO Companies' Load Management programs shall be excluded from the third-party administrator's area of responsibility.”

“Under the Non-Utility Market Structure, the commission would appoint a Public Benefits Fund ("PBF") Administrator to administer DSM programs, pursuant to Act 162, Session Laws of Hawaii (2006) ("Act 162"), which is codified in HRS § 269-121, et seq. 

The Non-Utility Market Structure is supported by the Consumer Advocate, HREA [Hawaii Renewable Energy Alliance], LoL [Life of the Land], and CoM [County of Maui]," with no opposition from DoD [Department of Defense].”

Energy Efficiency programs are now managed by Hawaii Energy

“Hawaii Energy is the ratepayer-funded conservation and efficiency program for Hawaii, Honolulu and Maui counties administered by Leidos Engineering, LLC under contract with the Hawaii Public Utilities Commission. We are here to help you save money on your electric bills and reduce our state's dependence on imported oil.”

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Sunday, February 7, 2016

NextEra SunPower Exchange Fires up Merger Proceeding

By Henry Curtis

Attorney Alvin B. Davis. Photo: Author

Alvin B. Davis was born in Rome, New York in 1942. He received his B. A. degree in American Studies from Syracuse University in 1964 and graduated from Yale Law School in 1967. He served as an U.S. Air Force JAG from 1968 to 1971. Davis was a partner in Steel Hector & Davis which merged with Squire Sanders & Dempsey in 2005.  Davis served as managing partner of Squire Patton Boggs’ Miami office from 2005 to 2010.
 The legal practice of Alvin Davis “focuses on high-profile, complex litigation, arbitration and international dispute resolution in the areas of securities and shareholder class actions, products liability, environmental claims, regulatory proceedings and a host of sophisticated contractual disputes.
 Alvin Davis has been listed in The Best Lawyers in America since 1991. In addition, he has been recognized among Florida’s Legal Elite by Florida Trend magazine each year since 2004 and listed among the top lawyers in Florida by the South Florida Legal Guide each year since 2005.
 In the HECO-NextEra merger proceedings, Davis cross-examined Dr. Tom Starrs, SunPower Corporation's vice president for market strategy and policy.

Tom Starrs. Photo: Linkedin
Tom Starrs made some general points in the first 20 minutes of the cross-examination.
 “Our interest is actually broader than our direct economic interest in the solar business here in Hawai`i. We also have a broader strategic interest in the proceedings going on here because we see Hawai`i, what Hawaii is doing  is a real bell weather for issues surrounding the integration of renewable energy resources, including distributed energy resources, not just here in Hawaii, not even just around the United States, but around the world.”
 “NextEra hasn't had an opportunity or hasn't availed itself of the opportunity, as far as I know, to gain much experience in integrating smaller scale distributed energy resources.”
 “We have a highly competitive market for distributed solar. There's companies represented in this room, many, many companies around the State of Hawai`i that have done a really admirable job in delivering solar energy services to customers, residents in the State of Hawai`i. And I don’t think it is clear that NextEra actually could do that work more effectively or more capably than they do.”
 Then about the 20 minute mark, Alvin Davis asked a long run-on question.
 “Well, did you observe, Mr. Gleason's statement in this proceeding, that NextEra's intensions were, to strengthen and accelerate HECO's clean energy transformation, consistent with this Commission's guidance as, expressed in its Inclinations, and its directives, consistent with Hawai`i energy policy, and consumer interests, and public policy goals, towards, more affordable, equitable and inclusive, economic, clean energy, clean energy future through, increased, renewable energy, including integrating more rooftop solar energy, electric grid modernization, energy storage, and customer demand and response programs, which seemed to be all the things you just mentioned?”
 I have tremendous respect for Mr. Gleason,” stated Starrs. “I don't question his sincerity. But I'd be much happier if we saw that language translated into specific policy proposals and initiatives in this proceeding that actually reflected those goals.”
 Mr. Starrs added, “I have been paying close attention to Hawai`i's energy policy for 20 years. And like Scott Hempling before me, I found the Inclinations White Paper to be one of the most extraordinary documents, that I have ever seen come out of a public utilities Commission. I thought it, I hoped that it heralded a significant shift in Hawai`i energy policy. Because I expected that both HECO, and later NextEra, would take advantage of the opportunity to respond to the Commission's preferences as stated in that document. And I was disappointed first in HECO's response, and then later I was disappointed in NextEra's response because I don't think that NextEra's proposals really materially reflected the explicit preferences that the Commission outlined in its Inclinations Paper.”
 Attorney Davis: “Well do you understand what the proceeding is here? That it's an effort to determine whether a merger acquisition merger can take place? Do you understand that?”
 Mr. Starrs: “In general, yes.”
 Attorney Davis: “Do you understand what the components of that are? Between parties such as this? The need to determine whether it's an organizational fit, whether it's a financial fit, whether it's an operational fit, whether it's a cultural fit, whether the companies can work together given the components that both bring to it. Do you understand that that's what the Companies have to consider to even determine if they want to proceed with a merger?”
 Mr. Starrs: “In general, yes.”
 Attorney Davis: “Do you understand the thousands of hours that are involved between companies of this size making the effort to determine whether that fit will occur?”
 Mr. Starrs: “In general, yes. I don't really see your point but.”
 Attorney Davis: “I'm hoping to get to it. My point is that this procedure is not intended to resolve the development of specific proposals to comply with the Inclinations of the Commission at this time.  The procedure is intended to satify
 SunPower Attorney Sandie Wong spoke up. “Mr. Chair. Is Mr. Davis testifying or is he asking a question? It seems like he's testifying, telling the witness what this procedure is meant to do. And with all respect to Mr. Davis, I think that is the place of the Commission and not Mr. Davis.”
 Attorney Davis: “I was responding to the witnesses question back of me wanting to see where I was getting to.”
 Chair Iwase: “Are you asking a question?”
 Attorney Davis: “I'm answering his question.”
 Chair Iwase: Why don't you ask a question?”
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Saturday, February 6, 2016

Four former utility commissioners to be cross-examined this week at HECO-NextEra Evidentiary Hearing

By Henry Curtis

Four former Commissioners are among the nearly 30 witnesses that are scheduled to be cross-examined by NextEra and HECO lawyers this week in the HECO-NextEra Contested Case Proceeding before the Hawai`i Public Utilities Commission. 
 If cross-examination of all witnesses is not completed by Wednesday, then a third round of the Evidentiary Hearing may be scheduled for the first week of March. 
 The four former Commissioners are County of Hawai`i witness Kristin Mayes, Sierra Club witness Nathan Skop, Blue Planet witness Ronald Binz and DBEDT witness Karl R. Rábago.

Speaking at the Institute of Electrical and Electronics Engineers (IEEE) Solar Energy Conference held at the Hawaii Convention Center in 2010, Mayes, the former Chair of the Arizona Corporation Commission stated that any commissioner who does not advocate for a sharp rise in the use of renewables should be fired.

Her message was that the utilities need to wake up and accept the new paradigm where they will become energy service providers instead of rigid advocates of the status quo. If they don’t change they will be bypassed.

Nathan A. Skop was a Business Manager for NextEra Energy from 2000-02 who went on to become a Commissioner for the Florida Public Service Commission. 

During his tenure on the Commission NextEra subsidiary Florida Power & Light Company (FPL) sought to disqualify Skop from all current and future proceedings.

“Florida Power & Light Company (FPL) moves to disqualify Commissioner Nathan Skop from participating as a member of the Public Service Commission (PSC or Commission) in PSC hearings, deliberations, decision-making, or acting in any other capacity, on all active dockets and matters involving FPL that have not yet been decided by the Commission …as well as any future dockets involving FPL that are opened in calendar year 2010.”

It was alleged that Florida Power & Light was upset that Skop did not rubber-stamp their excesses and abuses.

President Barack Obama nominated Ronald Binz to chair the Federal Energy Regulatory Commission (FERC). The coal industry defeated the nomination.

Ron Binz spoke at the Maui Energy Conference last spring and is a witness for Blue Planet Foundation in the Hawaii Public Utilities Commission decoupling docket.

Karl Rábago served as a Commissioner on the Public Utility Commission of Texas (PUCT) from 1992 to 1995.

As a municipal utility executive in Austin, Texas, Rábago led a team that came up with the very first value-of-solar tariff, an alternative to net-metering that aims to pay utility customers a rate for solar power that reflects its actual value to the grid and society.

Kristin Mayes is a Professor of Practice at Sandra Day O'Connor College of Law, a Senior Sustainability Scholar at the Julie Ann Wrigley Global Institute of Sustainability, and Professor of Practice at the School for the Future of Innovation in Society. Mays holds a Bachelor of Arts degree and a law degree from Arizona State University and received a Master of Public Administration from Columbia University.

While attending Arizona State University she served as editor in chief of the State Press, the university's newspaper. After graduation Mayes worked as a general assignment reporter for the Phoenix Gazette, and later as a political reporter for The Arizona Republic and then served as Communications Director for Arizona Governor Janet Napolitano.

Governor Napolitano appointed Kristin Mayes to the Arizona Corporation Commission in 2003. Mays won elections to the post in 2004 and re-election in 2006.  She termed out in 2010.

Mayes helped co-author the Arizona Renewable Energy Standard which requiring utilities by 2011 to acquire 30 percent of their energy from residential or non-utility owned installations, like rooftop solar panels on someone's home or on a shopping mall.

She also helped establish one of the most ambitious energy efficiency standards in the nation, requiring utilities to sell 22% less energy by 2020 than they would have under current forecasts.

Ronald Binz headed the Colorado Public Utility Commission from 2007 to 2011, where he was known for promoting renewable energy and efficiency, and for helping to draft a law that encouraged closing some old coal plants and cleaning up newer ones.

In 2012 Binz was the lead author of a CERES study: “Practicing Risk-Aware Electricity Regulation: What Every State Regulator Needs to Know How State Regulatory Policies Can Recognize and Address the Risk in Electric Utility Resource Selection.”

The paper argued for building wind farms and other sources of renewable energy as a hedge against future fossil fuel price increases and costly new pollution rules on burning coal or gas. Binz argued that renewable sources should be pursued even if they cost more than conventional ones.

Ceres was founded in 1989 when Joan Bavaria, then-president of Trillium Asset Management, formed an alliance with leading environmentalists with the goal of changing corporate environmental practices. She named the organization the "Coalition for Environmentally Responsible Economies" (CERES) after the Roman goddess of fertility and agriculture.

The vision of Ron Binz is that the Smart Grid should be viewed as an Electronic Organism. “If every device that touches the electric grid, every generation whether that’s small or large, every consumption…if every one of those is visible to the grid, it’s going to be more like an organism.”

The utility will be the “orchestra leader” who will coordinate all of the instruments. “The inputs and outputs are all going to be visible [to the utility] and controllable [by the utility]. That’s a completely different system than we’ve had before.

Ron Binz asserted that HECO would be like the National Security Agency (NSA). “The data that’s going to be produced by all of the sensors that are being installed as part of smart grid is going to produce a prodigious amount of data. The kind that NSA is probably accustomed to as they listen to all of our telephone calls.”

But Binz asserted that the information will be too vast for a utility to hone in on an individual. Rather the Smart Grid will be “machine-controlled, algorithm-driven.”

In Maui Ron Binz also talked about a theme he has developed over the years.

“I’ve been on the circuit talking about the smart grid for a number of years. Happily we’ve passed some of the hype. You all know about the stages of grief, well it’s the stages of smart grid. It started out kind of like magic a few years ago.”

“Everybody got in the game and we had a period of hype, unmitigated hype, the smart grid. I’d go to conferences and see all of these money grubbing people that I’d never seen before who had big plans for the smart grid.” “Then we had the crash, sort of despair. Oh it’s not going to work. Now we’re getting back to reality. Acceptance I guess is the term.”

Skop received a B.S. degree in Aerospace Engineering from the University of Florida, a Graduate Certificate in Environmental Management from Rensselaer Polytechnic Institute (RPI), a Master of Business Administration (M.B.A.), Finance (Financial Management and Investment Analysis) from RPI, an Executive Education Program, Mergers and Acquisitions from the Wharton School, University of Pennsylvania, and a law degree from the University of Florida - Fredric G. Levin College of Law.

His professional career includes working for Boeing Commercial Airplanes and for the General Dynamics Corporation Advanced Propulsion Plant Technology Program where his responsibilities included the design (conceptual through detail), integration, and test of nuclear submarine propulsion system turbomachinery while working in an integrated product team environment.

He is currently the Executive Vice President - Legal, Contracts & Compliance for the Merex Group | Kellstrom Defense Aerospace, Inc. Skop reports directly to the Chief Executive Officer. His responsibilities include managing all contracts, legal, risk management, regulatory compliance, security, and governmental affairs activities for Merex Group companies. Negotiate and manage agreements for worldwide Aerospace & Defense business operations. Support all corporate M&A activities including due diligence, document review, and management of external counsel. DOD Secret Security Clearance (active).

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Friday, February 5, 2016

Hawaii has Clear Energy Goals with Confusing Definitions

By Henry Curtis

The Administration has proposed HB 2291/SB 2820 which seeks to fix the renewable portfolio standard (RPS) which is used to measure the percentage of renewable energy sold by electric utilities.

This is critical because if the state wants to have a 100 percent renewable energy penetration by 2045, it is important to know what one means by renewable energy.

The bills state in their preamble, “Failure to address these issues would create the incorrect public perception of the State's progress towards its one hundred per cent renewable energy statutory goal.”

The bill “amends the ‘renewable portfolio standard’ definition to more accurately reflect the amount of renewable energy generation in Hawaii by amending the renewable portfolio standard calculation to be based on electrical energy generation as opposed to electrical energy sales.”

While the bills may appear to clear up some of the ambiguity, the result may still be confusing to some.

Biofuels are always renewable, even if they are made from fossil fuels.

Hydrogen made from fossil fuel can be considered renewable under certain circumstances.

Utilities can count savings from customer sited rooftop systems and commercial sea water air conditioning systems as if they were produced by the utility.

Fossil fuel used as inputs can become renewable energy.

The law requires HECO to increase its generation of electricity from renewables, but not the Gas Company, nor back-up generators at hospitals.

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Thursday, February 4, 2016

Ending Fossil Fuel Use in Hawai`i

By Henry Curtis

The 2001 state legislative session debated the concepts of Renewable Portfolio Standards and Net Energy Metering. At the end of the session, at the 11th hour, the two concepts were married in Act 272.

The Public Utilities Commission ended Net Energy Metering last October. 

HB 2575 was introduced in this session. The bill would fundamentally restructure the Renewable Portfolio Standards.

Since 2001 the concept of what is a renewable and how it should be counted in the Renewable Portfolio Standards calculation has changed on numerous occasions.

What hasn’t changed over time is the definition of fossil fuel. Long dead flora -- plant life -- is converted over eons to gas, solid and liquid fuel more commonly called natural gas, coal and petroleum.

As first pointed out by this author, and later agreed to by the Attorney General, and more recently by HECO, NextEra and the EUCI conference organizers, but not yet by the renewable energy sector in Hawai`i, under current RPS law it is possible for an electric utility to have an RPS exceeding 100 percent while still using substantial amounts of fossil fuel.

 The RPS law can be vastly simplified by focusing on  the use of fossil fuel rather than trying to define renewable energy and utilize bizarre formulas.

HB 2575 states that “All public utilities regulated by the public utilities commission shall have a maximum fossil fuel standard of: (1)Seventy-five per cent by December 31, 2020; (2)Forty per cent by December 31, 2030; and (3)  Zero per cent by December 31, 2045.

 "Fossil fuel standard" means the percentage of sales that is represented by fossil fuel."

Unlike the existing law, HB 2575 would equally apply to electric and gas utilities.

HB 2575 was introduced by Representative Chris Lee and is being heard today in the House Committee on Energy and Environmental Protection.

The Administration Bill, HB 2291, is not as strong as HB 2575.

While both bills fix the RPS formula, HB 2291 still relies on questions regarding what renewable energy is and isn’t.

Under state law, renewable energy currently is defined to include “hydrogen produced from renewable energy sources” and “biofuels” produced from any source including fossil fuels.

This biofuel exception was carved out about a decade ago when ethanol plants were proposed for Kauai and O`ahu. The ethanol plants would have used fossil fuel to convert plants into biofuels.

NextEra Energy recently revised their RPS commitment in the Public Utilities Commission’s HECO-NextEra merger proceeding.

NextEra Energy commits that each of the Hawaiian Electric Companies will undertake good faith efforts to achieve a consolidated renewable portfolio standard of thirty-five per cent of their net electricity sales by December 31, 2020, and fifty per cent of their net electricity sales by December 31, 2030. 

The Ka Lei Maile Ali`i Hawaiian Civic Club, an intervenor in the Public Utilities Commission’s HECO-NextEra merger proceeding, asked NextEra Energy a question on their RPS commitment.
KLMA asked, “If the definition of ‘net electricity sales’ was changed to ‘percent of electricity sold’ would that change the commitment?” 

NextEra responded, “This definitional change would deviate from the RPS law to which this commitment is tailored, in effect changing the commitment.”   

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Wednesday, February 3, 2016

Opposition to HECO-NextEra Deal is Widespread

By Henry Curtis

Chad Blair wrote a story today in Civil Beat analyzing support for the proposed NextEra acquisition of the Hawaiian Electric Companies.

Civil Beat hired Merriman River Group to conduct a poll of people’s attitudes towards the proposed acquisition.

Civil Beat surveyed 922 registered voters statewide Jan. 26-29. The poll, which sampled 70 percent landlines versus 30 percent cellphones, has a margin of error of 3.2 percent.
According to the new data, voter opposition to NextEra is consistent across a number of demographic groups including by gender, race and ethnicity, island location, political leanings and income levels.

Those identifying themselves as Democrats oppose the sale by more than 4 to 1.

The poll examined public attitudes towards the Public Utilities Commission and also how electric rates will change over the next ten years if the merger is approved 

Doesn’t Matter




Under 50
Over 50

Oahu CD-1
Oahu CD-2


Income < 50K
Income 50-100K
Income > 50K

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