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1°he Honorable Keith W. hue <br /> Page 2 <br /> December 8, 1993 <br /> Under these circumstances, we must not allow the residents- of the Island of <br /> Hawaii to face the risks that would arise from waiting until late 1996 or beyond for <br /> power provided by an 4PP. HELLO has learned, from the delays encountered by Puna <br /> Geothermal Venture, that the best-laid plans can go awry. So far, alt of the IPPs with <br /> which HELLO has existing firm power purchase contracts have either encountered <br /> delays in developing their projects or have had unexpected periods in which they have <br /> ceased production. <br /> Especially in Nght of this experience, HELLO believes that it is in the public's <br /> best interest, first, to build the 1995 generation unit at Keahole, and, second, to plan <br /> for the following generation unit through concurrent planning by HELLO fora utility- <br /> constructed addition along with discussions with IPPs proposing units in that time <br /> frame. In this way, the public will have better assurances that a reliable source of <br /> generation, providing power at a reasonable cost to the consumers, will be available <br /> when it is needed. <br /> would like to address the fourth paragraph of your comment letter, which <br /> states: <br /> " the statement on page 3-44 that the proposed expansion is consistent with <br /> the Sfate's land use classification is misleading. A generator station belongs in <br /> the urban district, 7-he existence of the generator station in the Conservation <br /> District is a result of unplanned historical circumstances. It v~ould be <br /> approprlat~' t® pe°t%tit'brl tl'B~ ,.and (15~ fioTrlrBllSSi®n t® rim®V~' tl7e parC~'I from th@ <br /> `COnservatl®n DlStrict.' <br /> H~LCO believes that the proposed expansion of the Keahole Generating <br /> Station should be permitted in this instance. °fhis conclusion is based, among other <br /> things, on the fiollowing: <br /> 1. I°BELCO constructed its generating station at Keahole in reliance upon a <br /> Conservation ®istrict Use Permit issued by the Board of Land-.and ~latural <br /> resources in ®ecember 1973. Subsequently, three C®UP amendments were <br /> issued by the Land Soard in February 1984, P~bruary 1987, and September <br /> 1988. Since 1973, excluding operating costs, HELLO has invested more than <br /> $10 million in the Keahole Generating Station in reliance upon the CDUP <br /> approval and amendments granted by the Land Soard over the -last 20 years. <br /> We believe it would be unfair and unreasonable to now require t~~LCO to <br /> pursee the State Land Use and County rezoning: approvals efor~; u~sder~aking <br /> the proposed expansion of the Keahole Generating Station.' a -also believe <br /> that this would be very detrimental to HELLO and would prejudice HELCO's <br /> <br /> •g ~ <br /> <br />