WCEC commented to the WUTC on Puget Sound Energy’s 2023 Electric Integrated Resource Plan Progress Report. While applauding the company’s progress toward a cleaner electric grid, the letter asks the Commission to engage an independent auditor, citing PSE’s continued preference for investor-friendly options over cost-effective DERs and demand-side measures.
- Virtual Power Plants could provide resource adequacy at 40–60% the cost of a gas peaker plant per a Brattle Group study, yet PSE’s Progress Report provides almost no VPP detail two years after the UTC granted PSE time to develop a VPP platform.
- The most popular sensitivity study chosen by PSE’s 2019 IRP Advisory Group — Vehicle-to-Grid — was never conducted; four years later WCEC is still waiting for the analysis while pilots advance in California, Colorado, New York, and North Carolina.
- PSE’s Time Varying Rates plans show high Achievable Technical Potential for summer-peak reduction but offer no pilot details or implementation dates.
- DER investment trails off after 2030: PSE’s plan shows DER Storage growing 43% and Demand Response 33% between 2030–2045, vs. 385% growth in DER Solar — a sporadic, back-loaded ramp.
- The letter requests the Commission engage an independent auditor to review PSE’s assumptions and analysis.