A87-610 Kamehameha Schools 2019 Motion for Modification and Time Extension
Exhibits 1-25 were submitted on July 24, 2019.
Exhibit # |
Description |
1 | Survey map, updated July 10, 2015, outlining the 1,395-acre KS Property reclassified to the State Land Use Urban District under Docket No. A87-610 |
2 | Graphic showing the State Land Use Districts of the KS Property, dated March 21, 2019 |
3 | Graphic showing City and County of Honolulu zoning districts of the KS Property, dated March 20, 2019 |
4 | Graphic showing Central Oahu Sustainable Communities Plan (2002) designations within the KS Property |
5 | Graphic showing Central Oahu Sustainable Communities Plan (proposed) designations within the KS Property |
6 | Graphic showing two-phase solar farm project within the KS Property approved by the Commission’s Order Granting Motion for Order Amending Findings of Fact, Conclusions of Law and Decision and Order Dated May 17, 1988, filed November 26, 2014 |
7 | Kamehameha Schools annual report to the Commission, dated May 29, 2019 |
8 | Conceptual Site Plan of the Waiawa Solar Power, LLC project site, dated July 9, 2019 |
9 | Information regarding battery systems and storage |
10 | Samsung Technical Specifications regarding battery energy storage system |
11 | NOVEC Technical Specifications Document on 3M Novec 1230 Fire Protection Fluid |
12 | Envirotemp FR3 Fluid Technical Specifications Document |
13 | Department of Health letter to Kamehameha Schools, dated March 28, 2019 |
14 | Waiawa Solar Farm Preliminary Engineering Considerations, by G70, dated July 19, 2019 |
15 | Construction Traffic Assessment for the Proposed Waiawa Solar Farm, by Fehr & Peers, dated July 19, 2019 |
16 | Waiawa Solar Power View Studies, by G70, dated March 2019 |
17 | Waiawa Solar Project Glint & Glare Analysis, by Capitol Airspace Group, dated March 26, 2019 |
18 | State Historic Preservation Division letter dated April 24, 2015 accepting Archeological Inventory Survey for the KS Property |
19 | Final Archaeological Preservation Plan (May 2015) by TCP Hawaii, LLC, and State Historic Preservation Division acceptance letter, dated September 14, 2015 |
20 | July 19, 2019, notification from TCP Hawaii, LLC to State Historic Preservation Division of proposed Waiawa Solar Power project and confirmation of installation of preservation fencing |
21 | Biological surveys for a solar electrical generating facility in Waiawa, Central Oahu, by AECOS, Inc., dated July 22, 2019 |
22 | Excerpt of the Honolulu Land Use Ordinance, Revised Ordinances of Honolulu, Chapter 21, Table 21-3 (Master Use Table) |
23 | Act 97 (2015) relating to renewable energy standards, approved by Governor Ige on June 8, 2015 |
24 | Press Release: Governor Ige signs bill setting 100 percent renewable energy goal in power sector, dated June 5, 2018 |
25 | KS Motion to Amend Service of Process Checklist, dated July 24, 2019 |
Successor Petitioner’s Exhibits 26 – 41 were filed on October 7, 2019, as supporting documents to the Motion for Modification and Time Extension and Memorandum in Support of Motion
Table of Contents (10/07/2019)
Exhibit No. Description
KS Exhibit 26 Part 1 Letter from Clearway Energy Group, LLC to the Department of the Navy, dated July 22, 2019
KS Exhibit 26 Part 2 Same as above
KS Exhibit 26 Part 3 Same as above
KS Exhibit 26 Part 4 Same as above
KS Exhibit 26 Part 5 Same as above
KS Exhibit 26 Part 6 Same as above
KS Exhibit 27 Letter from Department of the Navy to Clearway Group, LLC, dated September 30, 2019
KS Exhibit 28 Groundwater Impact Assessment for the Proposed Waiawa Solar Project, by Ford & Associates, Inc., dated October 5, 2019
KS Exhibit 29, Part 1 Biological surveys for the gen‐tie route from a solar electrical generating facility in Waiawa, central O‘ahu, by AECOS, Inc., dated September 24, 2019
KS Exhibit 29, Part 2 Same as above
KS Exhibit 30 Meeting Agenda and Meeting Minutes for Pearl City NB # 21 August 27, 2019 meeting
KS Exhibit 31 Meeting Agenda for Mililani / Waipio / Melemanu NB # 25 September 25, 2019 meeting
KS Exhibit 32 Materials Provided to Mililani Mauka NB #35 August 20, 2019
KS Exhibit 33 Resume of Jason A. Jeremiah, Kamehameha Schools
KS Exhibit 34 Resume of Patrick Sullivan, Clearway Energy Group LLC
KS Exhibit 35 Resume of Daniel von Allmen, Clearway Energy Group LLC
KS Exhibit 36 Resume of Paul T. Matsuda, G70
KS Exhibit 37 Resume of Jeffrey H. Overton, G70
KS Exhibit 38 Resume of Christopher M. Monahan, TCP Hawaii LLC
KS Exhibit 39 Resume of Dan Ford, Ford & Associates, Inc.
KS Exhibit 40 Resume of Eric B. Guinther, AECOS Inc.
KS Exhibit 41 Resume of Sohrab Rashid, Fehr & Peers
Certificate of Service Successor Petitioner’s First List of Exhibits (10/07/2019)
Successor Petitioner’s First List of Witnesses (10/07/2019)
Successor Petitioner’s Rebuttal Memorandum in Response to Office of Planning’s Response to Motion for Modification and Time Extension; Exhibits 42-44; Certificate of Service (11/04/2019)
Exhibit No. Description
KS Exhibit 42 Findings of Fact, Conclusions of Law and Decision and Order, filed May 17, 1988
KS Exhibit 43 Order Granting Motion to Amend Condition No. 6 of the Decision and Order Dated May 17, 1988, filed on November 30, 1990
KS Exhibit 43 Order Granting Motion for Order Amending Findings of Fact, Conclusions of Law and Decision and Order Dated May 17, 1988, filed on November 26, 2014
First Amended List of Witnesses; First List of Rebuttal Exhibits; Exhibits “45” – “48” (see below); Certificate of Service
Exhibit No. Description
KS Exhibit 45 Written direct testimony of Christopher M. Monahan / TCP Hawaii LLC / President, Archaeologist
KS Exhibit 46 Written direct testimony of Eric B. Guinther / AECOS Inc. / Senior Ecologist
Signature page of Mr. Guinther
KS Exhibit 47 Written direct testimony of Sohrab Rashid / Fehr & Peers / Traffic Engineer, Principal
KS Exhibit 48 Figure 1 (conceptual site plan) of Preliminary Civil Engineering Considerations report (KS Exhibit 14)
RECORDATION OF CONDITONS (04/21/2020)
Notice of Appearance of Counsel
PAUL S. AOKI, Brad T. Saito, and Molly A. Stebbins
Hawaiian Electric Company (12/10/19)
Pacific Resource Partnership (1/3/20)
Testimony from Paul Migliorato, Jeff Overton- Group 70, and Paul Sullivan (1/7/20)
Testimony from State of Hawaii Energy Office (1/07/20)
January 4-8, 2020 Public Comments
Troy Otsuka; Peter Breeze; Gary James; Peter Lee; Jon Grems; Jeff Mikulina (Blue Planet Foundation)
January 9, 2020 (submitted at LUC meeting)
PowerPoint presentation copy– Walter Thoemmes
Written testimony– Jeff Overton
LUC GENERATED
LUC letter to Petitioner re: Scheduling Motion Hearing (07/24/19)
LUC granting OP time extension request (08/06/19)
LUC filing schedule clarification letter (08/13/19)
PETITIONER GENERATED
Petitioner Request for clarification re LUC granting extension of time (08/09/19)
WAIAWA SOLAR POWER CORRESPONDENCE
Waiawa Master Plan (10/07/19)
Letter of Objection regarding the Findings of Fact, Conclusions of Law, and Decision and Order Granting with Modification Motion for Modification and Time Extension (filed February 11, 2020) (02/18/20)
Kamehameha Schools Bishop Estate re: status of Solar Project on property (09/02/20)