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In re Hawai'i Electric Light Co.

Hawaii Supreme Court
526 P.3d 329 (2023)

Written by Angela Patrick, JD

Facts

Hu Honua (plaintiff) was an energy company. Hu Honua applied to Hawaii’s Public Utilities Commission (PUC) for regulatory approval to build a biomass-fueled power plant to provide electricity to Hawaii Island. Hu Honua advocated that this plant would be better than fossil-fueled plants because the biomass fuel for this plant would be obtained by burning trees, a renewable resource. However, this mass tree burning would create significant greenhouse-gas emissions, which were known to have a negative impact on the environment. Hu Honua claimed the plant would be carbon-negative and argued this positive feature would offset the negative impact of the plant’s greenhouse-gas emissions. The PUC denied the application, finding that the greenhouse-gas emissions were too high relative to other renewable-energy options. Hu Honua appealed the administrative denial to the Hawaii Supreme Court, arguing that the PUC had improperly compared its proposal to other renewable-energy sources instead of just fossil-fueled power plants and had made its factual findings improperly.

Rule of Law

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Issue

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Holding and Reasoning (Eddins, J.)

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Concurrence (Wilson, J.)

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