HAWAIʻI FIRST

Itʻs Our Money: Approved Is Not Paid For – Hawaiʻi PUC and the $480 Million Question

On December 31, 2025, the Hawaiʻi Public Utilities Commission issued a 260-page order approving Hawaiian Electric’s 2025–2027 Wildfire Mitigation Plan.¹ The plan carries a price tag of roughly $480 million: covered conductors, vegetation clearing, asset inspections, weather stations, hazard cameras, a wildfire watch office.

Almost every account of that decision described it as approval of a $480 million program. That is not quite what happened.

The Commission approved the plan. Whether Hawaiian Electric may collect $480 million from its customers to pay for the plan is a separate proceeding, still open.² The company has said the average residential customer on Oʻahu would pay about $1 more per month, on Hawaiʻi Island about $3, and in Maui County about $5.³ Those are estimates attached to a request, not an approved charge.

The distinction between those two things — an approved project and an approved bill — is the entire subject of this post. If you want to know where Hawaiʻi’s infrastructure money actually goes, you have to understand the institution that stands between a utility’s proposal and your electric bill.

What the PUC is

The Commission is a three-member, quasi-judicial state body. Commissioners are appointed by the governor and confirmed by the Senate to six-year terms.⁴ Its jurisdiction covers electricity, gas, telecommunications, privately owned water and wastewater systems, interisland water carriers, and a large number of commercial passenger and freight carriers — roughly 1,800 regulated entities in all.⁵ It does not regulate county water departments, a distinction that trips up more people than you would expect.

In electricity, its authority is unusually consequential. Hawaiian Electric cannot decide on its own what infrastructure to build, what customers will pay for it, or what return its investors will receive. Those decisions run through the regulatory process.

Six powers matter most for anyone following the money.

1. It decides what customers may be charged.

Utility rates must be “just and reasonable” under state law, and Hawaiian Electric generally cannot raise them without Commission approval.⁶ The PUC determines both the total revenue the utility may collect and the mechanisms through which it collects it.

So the fundamental regulatory question is never “how much does the utility want to spend?” It is:

Will the PUC allow the utility to recover that money from ratepayers?

If yes, the expenditure eventually surfaces in electric bills. If the Commission finds an expenditure unnecessary, imprudent, or unreasonably priced, shareholders may absorb some or all of it instead. That is the difference between a cost and a recoverable cost, and it is where a great deal of money quietly changes hands.

2. It determines which investments ratepayers finance.

Major generation, transmission, distribution, storage, and grid-modernization expenditures typically require Commission review, or come under Commission scrutiny when the utility seeks cost recovery.

This is acutely live right now. Replacing poles, undergrounding lines, clearing vegetation, installing sensors, sectionalizing circuits, adding batteries, rebuilding transmission — all of it may be legitimate post-Lahaina safety work. But somebody pays. The Commission’s job is to test whether each expenditure is necessary, prudent, and reasonably priced, rather than passing everything through to customers as a matter of course.

The wildfire plan shows how granular this gets. Hawaiian Electric projects roughly $60 million to install covered conductors on about 56 miles of overhead line across Oʻahu, Maui, and Hawaiʻi Island — an average of roughly $1.07 million per mile, with more than half the mileage concentrated on Maui. Vegetation management and related inspections account for about $41.5 million; asset inspections and repairs, about $54.7 million. Another $89.1 million in wildfire-related grid modernization is being pursued in yet another docket, under an extraordinary project recovery mechanism.⁷

Those are the numbers a prudence review is supposed to interrogate. $1.07 million per mile is either reasonable or it isn’t, and the docket is where that gets argued.

3. It shapes what kind of electrical system Hawaiʻi gets — and what it buys.

The Commission oversees Hawaiian Electric’s Integrated Grid Planning process, which addresses where new generation is needed, what transmission and distribution improvements should be built, how much storage is required, where renewable projects connect, and how quickly fossil generation can retire.⁸

It also reviews major power-purchase agreements with independent solar, wind, geothermal, and storage developers. That matters because a twenty- or thirty-year contract commits Hawaiʻi ratepayers to hundreds of millions in future payments. The Commission has indicated that through 2030 Hawaiian Electric and KIUC anticipate applications covering more than 2,400 MW of hybrid solar, wind, and battery projects, plus more than 500 MW of firm generation, with individual agreements receiving their own dockets.⁹

The Commission therefore does not merely price electricity after the fact. It has substantial influence over the architecture of the system itself.

4. It sets the financial incentives Hawaiian Electric responds to.

This is the least understood of the PUC’s powers and arguably the most important.

Traditional cost-of-service regulation created a structural incentive to build: approved capital investments entered the rate base, on which the utility earned an authorized return. Build more, earn more.

Hawaiʻi has been moving away from that. Under the performance-based regulation framework established in Docket No. 2018-0088, Hawaiian Electric’s revenues, rewards, and penalties are increasingly tied to outcomes — cost control, renewable integration, customer service — through revenue adjustment mechanisms and performance incentive mechanisms.¹⁰

In principle, this stops the regulatory system from rewarding a utility simply for building expensive things. Whether it works in practice is an empirical question, and one worth testing against the wildfire program: roughly two-thirds of the $480 million is capital, one-third operations and maintenance.¹¹ Capital earns a return. O&M generally does not.

5. It regulates reliability and grid access.

The Legislature has authorized the Commission to adopt reliability standards and interconnection requirements by rule or order, and given it jurisdiction over interconnection matters and grid-access procedures.¹²

That determines whether and how rooftop solar, community solar, batteries, and independent producers connect to the grid. The same authority can accelerate distributed energy or throttle it. Rules on interconnection, hosting capacity, compensation for distributed generation, and required upgrades will largely decide whether Hawaiʻi’s energy system stays centralized around the utility or becomes meaningfully decentralized.

6. It is supposed to balance utility and public interests.

That is the reason PUCs exist at all.

Electric distribution is a natural monopoly. It would make no sense for three companies to string competing poles and wires down the same street. Because ordinary market competition cannot discipline such a monopoly, regulation substitutes for it.¹³

The bargain runs roughly like this. Hawaiian Electric receives an effectively exclusive service territory, relatively predictable revenues, access to capital, and the opportunity to earn a reasonable return. The public is supposed to receive reliable electricity, reasonable rates, adequate investment, nondiscriminatory service, safety, and protection from monopoly pricing.

The PUC is the institution standing between monopoly power and the ratepayer. That is a lot of weight for three commissioners to carry.

One player worth distinguishing: the Division of Consumer Advocacy. The Consumer Advocate participates in PUC cases on behalf of utility consumers, examines applications, and recommends approval, rejection, or modification. The Commission decides; the Consumer Advocate argues the consumers’ side.¹⁴ They are not the same office, and conflating them obscures who is actually accountable for a decision.

Why this matters for the money trail

Regular readers know the ladder I use for federal disaster money: appropriated → awarded → obligated → spent → built. Announcements happen at the top of that ladder. Concrete happens at the bottom. The gap between them is where accountability reporting lives.

Utility money has its own ladder, and it is longer:

proposed → docketed → approved → cost recovery authorized → collected from ratepayers → spent → built → return earned

The $480 million wildfire plan currently sits at rung three. It has been approved as a plan. It has not been approved as a charge. Nothing has been collected. And when money is eventually collected, the question of what was physically built with it is a separate inquiry again — one the Commission itself flagged, requiring Hawaiian Electric to adopt metrics tracking progress against targets and expenditures through 2027.¹

Here is a concrete gap I cannot yet close. Hawaiian Electric and the PUC have both said that roughly one-third of the $480 million is already funded through existing programs, including the federal grid resilience grant the company received in 2024. But reporting on the same filing indicates the company anticipates about $52 million in federal and state grant funding, putting net wildfire spending near $483 million for 2025–2027.⁷ Fifty-two million dollars is roughly eleven percent of $480 million, not a third.

These figures may be reconcilable — “existing programs” plausibly means work already authorized under other approved recovery mechanisms rather than grant-funded work. But as stated publicly, they are not the same claim, and the difference is on the order of $100 million. It also bears directly on a question I have been chasing for months: how much of the federal Grid Resilience and Innovation Partnerships award has Hawaiian Electric actually drawn down? Cost-recovery regulation should force that number into the open, because the company has to prove to the Commission exactly how much federal money offset its ratepayer request.

If federal money covers half a project, that tells us nothing on its own about what ratepayers pay. The remaining investment, the operating expenses, the financing costs, and the regulatory treatment all have to be traced through the dockets.

And there is a larger accountability question underneath all of this. The Commission can approve an expenditure that is entirely prudent as a legal matter and still leave unanswered whether Hawaiʻi got value for the money. The useful measure is not:

How much did the PUC approve?

It is:

How much was collected, how much was spent, what was actually built, who made money from it, and did reliability measurably improve?

That is why the dockets matter. They create a paper trail connecting corporate requests to public costs — one of the few places in Hawaiʻi infrastructure where that trail is required by law to exist.

What’s next

The next installment of this series will build a Hawaiian Electric–PUC Money Ledger: every major PUC-approved grid-hardening and wildfire expenditure since Lahaina, tracked across amount requested, amount approved, federal contribution, ratepayer contribution, contractor, actual expenditure, and physical work completed.

The starting points are the wildfire mitigation docket (2025-0156), its pending cost-recovery companion, and the extraordinary project recovery filing covering the $89.1 million in wildfire-related grid modernization.

That ledger should show, line by line, exactly where regulatory approval turns into money on the electric bill.


¹ Hawaiʻi Public Utilities Commission, Decision and Order No. 42228, Docket No. 2025-0156, “(1) Approving Hawaiian Electric Companies’ 2025-2027 Wildfire Mitigation Plan; (2) Providing Instructions for the 2026-2027 Wildfire Mitigation Plan Updates; and (3) Requiring Compliance With Areas for Continued Improvement,” filed December 31, 2025.

² Hawaiian Electric, “Regulators approve 3-year Hawaiian Electric Wildfire Safety Strategy,” December 31, 2025, noting that the overall cost is under consideration in a separate docket.

³ Figures reported in coverage of the December 31, 2025 announcement. [RB: confirm the source filing and the speaker’s title before publication.]

⁴ Hawaiʻi Public Utilities Commission, “What Is the PUC?”; Hawaiʻi Revised Statutes § 269-2.

⁵ Hawaiʻi Public Utilities Commission, “What Does the PUC Regulate?” and PUC Annual Report. [RB: the FY2024 annual report figure needs direct verification — I could not confirm 1,863. A secondary source gives 2,014 for FY2023 and the Commission’s own materials describe “over 1,800.” Pull the FY2024 PDF and cite the exact number.]

⁶ Hawaiʻi Revised Statutes § 269-16.

⁷ Cost breakdown as reported from Hawaiian Electric’s filing in Docket No. 2025-0156, including approximately $60 million for covered conductor across roughly 56 miles, $41.5 million for vegetation management and inspections, $54.7 million for asset inspections and repairs, $89.1 million in grid modernization pursued under a separate extraordinary project recovery docket, and approximately $52 million in anticipated federal and state grant funding. [RB: verify each line directly against the filing rather than the news summary.]

⁸ Hawaiʻi Public Utilities Commission, Integrated Grid Planning, Docket No. 2018-0165.

⁹ Hawaiʻi Public Utilities Commission, “Implementation of Executive Order No. 25-01.” [RB: the 2,400 MW and 500 MW figures need a direct cite to the Commission document.]

¹⁰ Hawaiʻi Public Utilities Commission, “Performance-Based Regulation for the Hawaiian Electric Companies,” Docket No. 2018-0088, and “Overview of the PBR Framework.”

¹¹ Hawaiian Electric, December 31, 2025 statement, describing approximately two-thirds capital investment and one-third operations and maintenance.

¹² Hawaiʻi Revised Statutes § 269-142 (reliability standards and interconnection requirements; note the statute is permissive — the Commission “may adopt” — rather than mandatory) and § 269-145 (grid access and interconnection procedures).

¹³ Hawaiʻi Department of Commerce and Consumer Affairs, Division of Consumer Advocacy, “DCA Overview/Services.” [RB: for the natural-monopoly proposition itself, consider a standard regulatory-economics citation instead of, or alongside, the DCA page.]

¹⁴ Hawaiʻi Department of Commerce and Consumer Affairs, Division of Consumer Advocacy, “FAQs” and “DCA Overview/Services.”


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