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Hawaii:  System Eligibility Policy - No 'Non-Export' Systems

Anita-PLR Product Ops avatar
Written by Anita-PLR Product Ops
Updated this week

Summary

This article provides an overview of Palmetto LightReach eligibility requirements for solar and storage systems in Hawaii, with a focus on how existing utility programs, export rules, and system configurations impact funding. It explains which HECO programs are supported, how NEM grandfathering is preserved, when storage or system replacements are allowed, and why non-export systems are excluded. The article also outlines requirements for second solar systems, documentation and compliance expectations, and key installation considerations to ensure projects remain eligible for funding under Palmetto LightReach.

Overview

  • Minimum System Size Palmetto LightReach will fund 3 kW DC

  • Storage is optional

  • Palmetto LightReach DOES NOT fund non-export systems

  • Any second PV system that is NEM+ non-export or limited-export will NOT be funded

  • NEM+ storage only additions (NO PV) to existing NEM system will be allowed

  • A second solar system must be completely separate with its own production monitoring. No adding new panels to an old inverter, no sharing of original equipment, this is also known as an Add-On.

  • For second systems, the first system must have PTO for at least 1 year.

  • BYOD Plus is optional at this time

Summary Table of Eligible HECO Program Types

  • No loss of NEM status - LightReach supports NEM customers maintaining grandfathering and DOES NOT fund systems where the NEM customer moves off NEM status.

Summary Table of Eligible System Configurations

Second Systems - Additional Information

  • Any second solar system must be completely separate with its own production monitoring. No shared inverters with the original system.

    • Palmetto DOES NOT fund existing system expansions using the existing system’s inverter, also known as an Add-On. It must be a separate system. See LightReach’s Eligible Sites

    • Palmetto will fund a new system that is a replacement of the entire existing system.

  • Palmetto LightReach funds second systems on existing DG programs that allow exports to the grid, including:

    • Smart Renewable Energy Export (Smart DER Export)

    • Customer Grid Supply (CGS)

    • Customer Grid Supply Plus (CGS+)

    • Smart Export

    • NEM replacements (amendments) — however, not NEM+

      • Palmetto requires proof of

        • Utility bill stating NEM (all pages)

          • NEM bill example

          • Rate Plan will likely state R Residential Service Signed NEM Contract, or R Residential TOU Signed NEM Contract

        • Copy of an email from HECO stating the original NEM Facility’s Capacity and Inverters on file

        • Proof of Interconnection Approval as a NEM Replacement

  • Palmetto LightReach DOES NOT fund non-export systems.

    • No NEM Plus (NEM+)

      • No 2nd system or capacity additions on NEM+ at this time.

    • No loss of NEM status - LightReach supports NEM customers maintaining grandfathering and DOES NOT fund systems where the NEM customer moves off NEM status.

    • No Customer Self-Supply (CSS) or Smart Renewable Energy Non-Export Systems (Smart DER Non-Export)

      • However, Self-Supply customers may optionally transition to Smart Renewable Energy Export (Smart DER Export), and then Palmetto will fund the new second system also on Smart DER Export.

M1 Installation Package Considerations

  • Only systems with AVL approved and FEOC eligible products will be funded

    • The ITC Calculator is the Source of Truth, please use this to validate compliance

    • In addition, photo documentation of equipment and/or an invoice must be provided

      • PLR needs to be able to match what was installed on site with what was selected in the ITC Calculator

Review and comply with all M1 checklist items which include, but is not limited to:

  • Utility Bill - A complete copy of the utility bill with all pages is required for second systems. This shall include the 12-month trailing Usage and Billing details.

    • For NEM - NEM bill example

      • Rate Plan will likely state R Residential Service Signed NEM Contract, or R Residential TOU Signed NEM Contract

      TOU Signed NEM Contract

  • Interconnection Application - A complete copy showing all pages, especially those that indicate the program that is being applied to

    • Reminder no Non-Export Systems will be funded (no NEM+, No CSS, No Smart DER Non-Export)

    • Reminder customers with NEM must maintain NEM grandfathering (Palmetto LightReach will fund NEM capacity replacements and Storage additions)

  • If existing NEM system is present, need copy of an email from HECO stating:

    • Site address

    • Original NEM Facility’s Capacity

    • Inverters on file

  • 2nd System Requirements:

    • All OEM AC coupled system sizing limits must be maintained

    • A second solar system must be completely separate with its own production monitoring. No adding new panels to an old inverter, no sharing of original equipment, this is also known as an Add-On

    • Consider additional monitoring equipment that will be required on the existing system to ensure the new system operates per OEM guidelines.

    • IF the the existing system is Enphase the below requirements MUST be followed when the NEW system is also Enphase:

      • Additional set of CTs. Further information regarding second systems and their proper configuration will be available in the Palmetto Knowledge Base and through OEMs.

      • In-line filter needs to be installed in its own enclosure on the (N) Enphase system after combiner and before POI. Contact Enphase to ensure the correct filter is utilized. Also, ensure all install instructions are followed and filters are properly grounded.

      • (N) AC conductors from microinverters on roof to (N) combiner must have > 12" of separation from (E) Enphase AC conductors (micros to combiner)

      • Can NOT use the same conduit for (N) + (E) AC conductors (micros to combiner)

Verifying Eligibility of Original System:

Original System is NEM

  • NEM projects were Installed before October 12, 2015

  • Palmetto LightReach funds both:

    • NEM replacements to the Existing NEM Facility with the SAME capacity.

      • HECO allows existing NEM facilities to be replaced and stay on NEM. HECO also allows the addition of 1 kW capacity (or 1,000W on HI islands) as measured as the lesser of kW AC or DC of the original NEM facility. Add PV as an ‘Amendment’ in HECO’s Customer Interconnection Tool.

      • Storage is optional on NEM replacements.

  • Palmetto LightReach DOES NOT fund:

    • NEM capacity additions, also known as an Add-On to an existing system, using the existing system’s inverter(s).

    • NEM+, except for Storage Only under our Backup Battery Lease Agreement

    • Losing NEM status by moving the customer to an alternate DG program

Original System Installed is CGS, CGS+

  • Installed after October 12, 2015

  • One of these programs providing just 7 years of grandfathering

  • Adding PV capacity to the meter DOES NOT end grandfathering early

  • Customers may opt to transition early to Smart DER Export. It is often more beneficial to the customer to transition early, however, is not required.

  • If storage is present, the battery mode shall be set to Self-Consumption (Self-Powered).

  • Palmetto requires proof of

    • Utility bill stating the program (all pages)

    • Standard Hawaii Lease Agreement including performance guarantee

      • Full Services Backup Battery or Energy Arbitrage Battery funded

    • PTO email/letter stating the new DG program

Original System is on Customer Self-Supply:

  • Installed after October 12, 2015

  • Self-Supply non-export system:

  • HECO’s policy is that CSS customers can stay on CSS, opt into Smart DER Export, or opt into Smart DER Non-Export

    • In order to transition to Smart DER Export, HECO requires old and new equipment to be eligible for Smart DER Export on their eligible equipment list.

  • Palmetto requires CSS customers transition to Smart DER Export to enable exporting to the grid when the storage system is full instead of curtailing.

  • If storage is present, the battery mode shall be set to Self-Consumption (Self-Powered).

  • Palmetto requires proof of

    • Utility bill stating the Self-Supply program (all pages)

    • Standard Hawaii Lease Agreement including performance guarantee

      • Full Services Backup Battery or Energy Arbitrage Battery funded

    • PTO email stating the new Smart DER Export program approval

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