WCEC submitted additional comments to the WUTC on Puget Sound Energy’s 2023 Gas Utility Integrated Resource Plan (Docket UG-220242), identifying significant cost-analysis errors that bias the company toward its preferred natural-gas-heavy portfolio. The letter asks the Commission to reject the IRP and engage an independent analyst to review PSE’s facts and forecasts.
- PSE’s Electrification Scenario emits ~0.8 million metric tons more gross emissions than its Preferred Portfolio — an outdated demand assumption that makes electrification appear ~$200M more expensive than it should.
- PSE acknowledged that the same hydrogen volume should not appear in both portfolios despite different gas demand — an error the company said would be reflected in future modeling.
- PSE’s 6.8% discount rate inflates early investments, biasing against transformative plans; at 2.0% (better-suited to intergenerational impacts), the two portfolios reach cost parity.
- PSE’s Preferred Portfolio would have customers emitting ~4 million metric tons of CO₂-equivalent in 2050 — roughly 90% of the state’s entire allowable emissions budget under the Climate Commitment Act.
- PSE did not adequately incorporate Time Varying Rates, Critical Peak Pricing, or Virtual Power Plants — proven 40–60% cheaper than gas peaker plants — into its Electrification Scenario cost analysis.