WCEC challenged Puget Sound Energy’s unexplained 50% derate of estimated peak reduction from its Time Varying Rate (TVR) programs in the Draft Clean Energy Implementation Plan. The filing notes that PSE’s own consultant — the Brattle Group — never recommended derating TVR benefits, and asks the UTC to require a clear explanation before allowing the derate to delay TVR adoption.
- PSE’s Draft CEIP Table 4-2 cuts estimated peak reduction from each TVR pilot in half, justifying it only via a single footnote stating PSE’s system is “winter-peaking.”
- The Brattle Group, PSE’s own TVR consultant, did not propose derating in any of the presentations WCEC attended.
- Slower TVR adoption would delay or eliminate the need for a new peaker plant PSE wants to begin building shortly — a financial incentive PSE has to slow-walk TVR deployment.
- TVRs have been a six-year focus for WCEC members, partly stemming from the Energize Eastside debate where coalitions argued ambitious Demand Response could eliminate the need for the costly transmission upgrade.
- The filing asks the Commission to demand a clear justification for the derating and, absent that, require faster TVR adoption.