Scoping for Battery Energy Storage Systems Programmatic Environmental Impact Statement
To the Department of Ecology, Clean Energy Coordination:
My name is Bruce Carlson and I live at 7023 Laurel Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live on Snoqualmie Ridge, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
I am not opposed to battery technology. I am very concerned about the location. I am concerned about safety from fire and how power for the facility will impact our utility rates. Plus, other facilities have turned out to have unforeseen effects on local communities.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Bruce Carlson
7023 Laurel Ave SE↓
My name is Bruce Carlson and I live at 7023 Laurel Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live on Snoqualmie Ridge, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
I am not opposed to battery technology. I am very concerned about the location. I am concerned about safety from fire and how power for the facility will impact our utility rates. Plus, other facilities have turned out to have unforeseen effects on local communities.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Bruce Carlson
7023 Laurel Ave SE↓
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I have lived on this earth for many decades and yet it still amazes me how incredibly inept our "leaders" are when it comes to community safety.
There is nothing ecologically friendly or safe about a BESS site. How many times must there be a runaw...↓ay thermal event and subsequent ecological damage before a state as beautiful and pristine as Washington gets a clue how dangerous they really are to this earth and it's inhabitants?
NO BESS anywhere in WA state!
A battery thermal-runaway event must not be evaluated solely as a fire-code or emergency-response matter when the credible consequences of that event may affect SEPA environmental elements.
The PEIS should clearly distinguish fire-code compliance from environmental review. Compliance with the International Fire Code, NFPA 855, UL 9540, UL 9540A, or approval by a local fire authority does not by itself evaluate probable impacts to air quality, soils, surface water, groundwater, critical aquifer recharge areas, wetlands, fish and wildlife, neighboring communities, transportation, evacuation routes, or public services.
Ecology should specifically address the risk that project-level lead agencies may characterize thermal-runaway consequences primarily as fire-safety matters and defer analysis of their environmental effects to later Hazard Mitigation Analyses, Emergency Response Plans, fire permits, building permits, or construction-stage review.
Where those consequences are reasonably foreseeable and relevant to determining whether a proposal may have significant adverse environmental impacts, the environmental analysis should occur early enough to inform the SEPA threshold determination and any discretionary land-use approval. Later fire-code or building-code review should supplement, not substitute for, the environmental review required under SEPA.
The PEIS should therefore provide clear guidance identifying which consequences of credible BESS failure scenarios must be addressed during SEPA review, even when separate fire, building, or emergency-response regulations also apply.
An environmental consequence does not cease to be a SEPA consequence merely because its initiating event is regulated by the fire code.↓
There is nothing ecologically friendly or safe about a BESS site. How many times must there be a runaw...↓ay thermal event and subsequent ecological damage before a state as beautiful and pristine as Washington gets a clue how dangerous they really are to this earth and it's inhabitants?
NO BESS anywhere in WA state!
A battery thermal-runaway event must not be evaluated solely as a fire-code or emergency-response matter when the credible consequences of that event may affect SEPA environmental elements.
The PEIS should clearly distinguish fire-code compliance from environmental review. Compliance with the International Fire Code, NFPA 855, UL 9540, UL 9540A, or approval by a local fire authority does not by itself evaluate probable impacts to air quality, soils, surface water, groundwater, critical aquifer recharge areas, wetlands, fish and wildlife, neighboring communities, transportation, evacuation routes, or public services.
Ecology should specifically address the risk that project-level lead agencies may characterize thermal-runaway consequences primarily as fire-safety matters and defer analysis of their environmental effects to later Hazard Mitigation Analyses, Emergency Response Plans, fire permits, building permits, or construction-stage review.
Where those consequences are reasonably foreseeable and relevant to determining whether a proposal may have significant adverse environmental impacts, the environmental analysis should occur early enough to inform the SEPA threshold determination and any discretionary land-use approval. Later fire-code or building-code review should supplement, not substitute for, the environmental review required under SEPA.
The PEIS should therefore provide clear guidance identifying which consequences of credible BESS failure scenarios must be addressed during SEPA review, even when separate fire, building, or emergency-response regulations also apply.
An environmental consequence does not cease to be a SEPA consequence merely because its initiating event is regulated by the fire code.↓
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I am apposed to the BESS energy storage facilities in Thurston county areas. This is a potential hazard to the environment and has not proven to have any control methods that are long term and fully
controlable to the opinion of many residents. As a...↓ resident of Tenino, we have faced one facility in Grand Mound that was discontinued and the current proposed facility is in Bucoda. We have a small one in Tenino. Major salmon baring rivers and elk herds are at one location as are schools, homes, bus barns, farms in the others. I do not believe the energy stored by the batteries will ever give our small communities any boost to our energy grid. There is plenty of open spaces away from our precious towns that we so cherish. Thank you
Nina Dickison↓
controlable to the opinion of many residents. As a...↓ resident of Tenino, we have faced one facility in Grand Mound that was discontinued and the current proposed facility is in Bucoda. We have a small one in Tenino. Major salmon baring rivers and elk herds are at one location as are schools, homes, bus barns, farms in the others. I do not believe the energy stored by the batteries will ever give our small communities any boost to our energy grid. There is plenty of open spaces away from our precious towns that we so cherish. Thank you
Nina Dickison↓
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I don't understand how anyone can believe that these BESS facilities are safe for the environment or our communities. Just look at Moss Landing as ONE EXAMPLE OF MANY DANGERS these facilities pose.
Moss Landing has had multiple incidents. Until ther...↓e are safe options, NO BESS ANYWHERE IN WASHINGTON STATE!
A battery thermal-runaway event must not be evaluated solely as a fire-code or emergency-response matter when the credible consequences of that event may affect SEPA environmental elements.
The PEIS should clearly distinguish fire-code compliance from environmental review. Compliance with the International Fire Code, NFPA 855, UL 9540, UL 9540A, or approval by a local fire authority does not by itself evaluate probable impacts to air quality, soils, surface water, groundwater, critical aquifer recharge areas, wetlands, fish and wildlife, neighboring communities, transportation, evacuation routes, or public services.
Ecology should specifically address the risk that project-level lead agencies may characterize thermal-runaway consequences primarily as fire-safety matters and defer analysis of their environmental effects to later Hazard Mitigation Analyses, Emergency Response Plans, fire permits, building permits, or construction-stage review.
Where those consequences are reasonably foreseeable and relevant to determining whether a proposal may have significant adverse environmental impacts, the environmental analysis should occur early enough to inform the SEPA threshold determination and any discretionary land-use approval. Later fire-code or building-code review should supplement, not substitute for, the environmental review required under SEPA.
The PEIS should therefore provide clear guidance identifying which consequences of credible BESS failure scenarios must be addressed during SEPA review, even when separate fire, building, or emergency-response regulations also apply.
An environmental consequence does not cease to be a SEPA consequence merely because its initiating event is regulated by the fire code.↓
Moss Landing has had multiple incidents. Until ther...↓e are safe options, NO BESS ANYWHERE IN WASHINGTON STATE!
A battery thermal-runaway event must not be evaluated solely as a fire-code or emergency-response matter when the credible consequences of that event may affect SEPA environmental elements.
The PEIS should clearly distinguish fire-code compliance from environmental review. Compliance with the International Fire Code, NFPA 855, UL 9540, UL 9540A, or approval by a local fire authority does not by itself evaluate probable impacts to air quality, soils, surface water, groundwater, critical aquifer recharge areas, wetlands, fish and wildlife, neighboring communities, transportation, evacuation routes, or public services.
Ecology should specifically address the risk that project-level lead agencies may characterize thermal-runaway consequences primarily as fire-safety matters and defer analysis of their environmental effects to later Hazard Mitigation Analyses, Emergency Response Plans, fire permits, building permits, or construction-stage review.
Where those consequences are reasonably foreseeable and relevant to determining whether a proposal may have significant adverse environmental impacts, the environmental analysis should occur early enough to inform the SEPA threshold determination and any discretionary land-use approval. Later fire-code or building-code review should supplement, not substitute for, the environmental review required under SEPA.
The PEIS should therefore provide clear guidance identifying which consequences of credible BESS failure scenarios must be addressed during SEPA review, even when separate fire, building, or emergency-response regulations also apply.
An environmental consequence does not cease to be a SEPA consequence merely because its initiating event is regulated by the fire code.↓
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What about all responders, ie police and ecology needing self-contained breathing apparatus (SCBA) in order to operate during a BESS catastrophic failure? Should residents be prepared with self-contained breathing apparatus (SCBA).
During the MOSS L...↓anding meeting with county council in 2025, most residents were not notified to either evacuate or shelter in place. There was no air monitoring for HF. One child was taken to a doctor to see about a rash, the doctor could not help her without knowing what the child had been in contact with. The county council member kept telling residents to see their doctor if they have symptoms, but the doctors can't do anything not knowing what the patient has been in contact with. The residents were told not to worry about the smoke when in fact the smoke contained HF. How can all residents be made aware of an evacuation or shelter in place. Some residents had livestock - what happens to the livestock? What happens to the farms that surround MOSS Landing? What about the contamination of the food? Do we need raid sirens to notify everyone? What about alerts on cell phones - for everyone.
None of the cost for the BESS should be burdened by the residents, 100% paid for by the companies that are causing the push for more BESS.
Who is going to pay for the devaluation of homes?↓
During the MOSS L...↓anding meeting with county council in 2025, most residents were not notified to either evacuate or shelter in place. There was no air monitoring for HF. One child was taken to a doctor to see about a rash, the doctor could not help her without knowing what the child had been in contact with. The county council member kept telling residents to see their doctor if they have symptoms, but the doctors can't do anything not knowing what the patient has been in contact with. The residents were told not to worry about the smoke when in fact the smoke contained HF. How can all residents be made aware of an evacuation or shelter in place. Some residents had livestock - what happens to the livestock? What happens to the farms that surround MOSS Landing? What about the contamination of the food? Do we need raid sirens to notify everyone? What about alerts on cell phones - for everyone.
None of the cost for the BESS should be burdened by the residents, 100% paid for by the companies that are causing the push for more BESS.
Who is going to pay for the devaluation of homes?↓
No attachments
October 1, 2026
Clean Energy Coordination
Washington State Department of Ecology
PO Box 47709
Olympia, WA 98504-4709
**Re: Scoping Comments on the Battery Energy Storage System Facilities Programmatic Environmental Impact Statement (Publication 26-...↓06-017)**
Dear Clean Energy Coordination Team,
The rapid proliferation of utility-scale lithium-ion BESS proposals necessitates a rigorous, impartial, and scientifically grounded analysis of the significant adverse environmental impacts these facilities pose, particularly when sited near sensitive receptors.
This PEIS is especially critical in light of the proposed Cascadia Ridge Resiliency Energy Storage project by Jupiter Power LLC, a Texas-based company. This project would place an approximately 130 MW utility-scale lithium-ion BESS on a ~45-acre parcel of unincorporated King County land south of Fisher Creek Park, directly adjacent to the City of Snoqualmie and in close proximity to Cascade View Elementary School, residential neighborhoods, and agricultural lands. Jupiter Power has announced its intention to seek approval through the state Energy Facility Site Evaluation Council (EFSEC), bypassing local King County land use authority and underscoring the vital importance of robust statewide standards established by this PEIS.
Local concerns are already significant. The Snoqualmie Valley School District Board of Directors has formally called for an expanded environmental review of the Cascadia Ridge project, citing profound concerns for student safety and emergency preparedness. These concerns are echoed in Ecology's own scoping document, which acknowledges that stand-alone BESS "could be sited in a variety of locations," including near cities—a stark contrast to the previous solar and wind PEISs, which studied facilities "not likely to be located in or near cities." The scoping document rightly identifies public concerns raised about "adequate training and equipment for local responders, the difficulty of extinguishing fires, risks of hazardous air emissions, impacts to water and fish, and cleanup."
This letter outlines critical environmental, health, and safety factors that must be comprehensively evaluated in the PEIS.
### **1. Thermal Runaway Fire Risks and Toxic Contamination**
Lithium-ion BESS facilities present a unique and severe fire risk profile characterized by thermal runaway—a self-propagating, exothermic chain reaction where internal heat generation exceeds dissipation, causing cascading cell failure. Once initiated, this "domino effect" can spread to adjacent cells and modules, often resulting in intense, high-temperature fires that can burn for days and resist conventional extinguishment methods.
**1A. Fire Behavior and Toxic Gas Emissions**
The Klickitat County Utility-Scale BESS Report (May 2025) correctly summarizes the danger: "Fumes from a BESS fire contain hazardous chemicals that are toxic and dangerous resulting in necessary evacuation procedures for the surrounding neighborhood... Potentially hazardous chemicals released during the fire can pollute the water used to fight it and contaminate the surrounding soil or groundwater as it absorbs the runoff."
A primary chemical of concern is hydrogen fluoride (HF), a highly toxic gas. According to a Massachusetts state toxicology report, "The release of hydrogen fluoride from a Li-ion battery fire can therefore be a severe risk..." Upon contact with moisture in the eyes, skin, or lungs, HF forms hydrofluoric acid, an extremely corrosive substance that can cause deep tissue burns, bone damage, systemic toxicity (hypocalcemia), cardiac arrhythmia, and death. Civilians, and particularly children at nearby schools, have no protective equipment against such an exposure. The 2024 Otay Mesa fire in San Diego, which burned for 11 days, serves as a grim example; Cal Fire reported that lethal amounts of hydrogen cyanide were detected in the air within three hours of ignition.
**PEIS Requirement:** The PEIS must model the atmospheric dispersion of toxic gases—including hydrogen fluoride, hydrogen cyanide, and heavy metal particulates—from a catastrophic thermal runaway fire. These models must account for worst-case meteorological conditions, such as the temperature inversions common in the Snoqualmie Valley, which trap pollutants near ground level and can significantly expand the area of public health impact.
**1B. Soil and Groundwater Contamination from Firefighting Runoff**
The aftermath of a BESS fire presents a significant environmental contamination risk. Recent scientific evidence from the January 2025 Moss Landing BESS fire in California confirms this threat. Researchers from Moss Landing Marine Laboratories detected elevated levels of nickel, cobalt, and manganese in Elkhorn Slough soils following the fire. Their study estimated that approximately 25 metric tons (55,000 pounds) of heavy metals were deposited across roughly half a square mile of wetland. Critically, while surface concentrations dropped after rain events washed the toxic dust away, the researchers concluded that "the metals did not disappear," implying migration into the broader ecosystem. A separate study by the University of California Agriculture and Natural Resources evaluated the deposition of cobalt, copper, nickel, and manganese in agricultural fields, underscoring the direct threat to food production.
The Snoqualmie area's hydrogeology makes it exceptionally vulnerable. The area has two distinct aquifer systems: a shallow, unconfined aquifer in the Tokul Creek alluvial fan at depths of less than 35 feet, and a deeper aquifer at 70-170 feet. Many residents in the area rely on private wells for their drinking water.
**PEIS Requirement:** The PEIS must rigorously analyze the contaminant transport pathways of fire-suppression water and dissolved heavy metals from a BESS site to local groundwater, private wells, and fish-bearing streams. This analysis must account for local soil permeability, infiltration rates, and aquifer characteristics.
**1C. Air Quality Impacts**
The Snoqualmie Comprehensive Plan notes that "Snoqualmie is relatively free from air pollution" due to its rural setting. A BESS fire would represent an acute and catastrophic degradation of this air quality baseline, releasing a toxic plume of particulates and hazardous gases into the community.
**PEIS Requirement:** The PEIS must analyze how a BESS fire would degrade local air quality, particularly under valley inversion conditions that concentrate pollutants.
**1D. Failure Rate Data Limitations**
Industry assurances of BESS safety often rely on flawed and incomplete data. As documented in NIST Technical Note 2365 (March 2026), "Understanding the Risk of Lithium-Ion Battery Fires," the primary incident databases (UL, Tesla, EPRI) are "built on a deeply flawed foundation" because they are compiled from media reports and other public documents rather than systematic, mandatory incident reporting. The EPRI BESS Failure Incident Database methodology explicitly states this reliance on public sources. Furthermore, 72 of the 164 incidents in the EPRI database lack a MWh value, the key parameter for calculating a meaningful failure rate based on stored energy (GWh), not simply power flow (GW).
**PEIS Requirement:** The PEIS must reject reliance on industry-funded or media-derived incident data. It must disclose the funding source of all datasets used, demand independent safety data, and require as mitigation compliance with the most recent safety standards (e.g., UL 9540A, NFPA 855), regardless of state adoption status.
### **2. Siting, Proximity, and Compounded Hazards**
The core issue is that BESS facilities are industrial-scale chemical installations with inherent catastrophic failure modes, yet they are being proposed in and adjacent to residential, recreational, agricultural, and environmentally sensitive areas.
**2A. Proximity to Sensitive Receptors**
The proposed Cascadia Ridge site is a textbook example of inappropriate siting, located near Cascade View Elementary School, established residential neighborhoods (Snoqualmie Ridge), parks (Fisher Creek Park), and rural farms. The Washington State Department of Commerce's own *Energy Safety Resources* guide advises local governments to "Set minimum distances between a facility and nearby homes, schools, parks, waterways and property lines."
Proximity to a substation should not be the primary determinant of site suitability. While Ecology's scoping document notes it may consider proximity to existing infrastructure, this logic is dangerously flawed. In many Washington communities, that infrastructure is co-located with homes, schools, and water supplies.
**PEIS Requirement:** Suitability must be defined by safety criteria first. The PEIS must establish a framework that prioritizes human health and environmental safety over grid convenience, with enforceable, scaled setbacks.
**2B. Critical Areas and Aquifer Protection**
Local and county regulations explicitly protect the water resources threatened by the Cascadia Ridge proposal.
* **City of Snoqualmie Sensitive Areas Ordinance (SMC 19.12):** Defines a "Critical aquifer recharge area" as a source of drinking water with "no feasible alternative source" that is "susceptible to contamination from activities on the surface" due to "high infiltration rates."
* **Snoqualmie Comprehensive Plan:** Warns, "Once ground water is contaminated it is difficult, costly and sometimes impossible to restore. Groundwater resources must be protected from contamination..."
* **King County Code (KCC):** Restricts building in Critical Areas "to protect public health and safety, and to promote environmental health." The county defines Critical Aquifer Recharge Areas as those "susceptible to groundwater contamination."
**PEIS Requirement:** The PEIS must explicitly screen out Critical Aquifer Recharge Areas, areas dependent on private wells, floodplains, and seismic hazard zones from the geographic scope of "suitable" BESS sites.
**2C. Seismic Hazards**
The Snoqualmie Comprehensive Plan states, "Most of the upper Snoqualmie Valley... is a seismic hazard area," with saturated sandy soils on the Snoqualmie River floodplain that may be "susceptible to liquefaction." An earthquake is a critical initiating event that is not captured by standard operational failure rates. A seismic event could damage multiple battery enclosures simultaneously while disabling the grid, cooling systems, monitoring equipment, and fire suppression systems. This represents a common-cause failure scenario where emergency crews would be overwhelmed and access routes compromised.
**PEIS Requirement:** The PEIS must analyze earthquakes as a common-cause failure scenario, evaluating the simultaneous failure of containment, cooling, and suppression systems, as well as the impairment of emergency response.
**2D. Flooding**
The Snoqualmie River experiences the largest peak flows of any river in King County. Flooding could compromise containment systems, mobilize and spread contaminated runoff across a wide area, and render emergency response impossible.
**2E. Evacuation Capacity**
The Snoqualmie Ridge community has notoriously limited access routes. The landslide on December 10, 2025, that closed eastbound I-90 demonstrated how a single event can paralyze the local road network for hours.
**PEIS Requirement:** The PEIS must evaluate evacuation capacity as a critical aspect of public health and safety. It should require modeled evacuation time estimates for surrounding populations and recommend against siting BESS where a timely evacuation cannot be assured.
### **3. Insurance, Financial Assurance, and Liability Gaps**
A significant policy gap exists regarding financial responsibility for a catastrophic BESS incident. Washington's battery stewardship law (Chapter 70A.555 RCW) explicitly excludes BESS batteries, leaving no dedicated program for their end-of-life management or post-incident cleanup. There are currently no specific BESS insurance, cleanup bond, or decommissioning financial assurance requirements in Washington state law.
**PEIS Requirement:** The PEIS must analyze the profound question of liability: Who is responsible for environmental cleanup after a fire? What insurance limits are adequate for a multi-week fire and widespread contamination event? What happens if the operator is a limited liability entity that declares bankruptcy, leaving local communities and property owners to bear the cost? The PEIS should recommend mandatory, robust financial assurance requirements, including:
* Developer-funded environmental monitoring programs.
* Cleanup guarantees and bonds funded *before* operation begins.
* Decommissioning bonds sufficient to cover full site restoration, including soil and groundwater remediation.
* Pollution liability insurance with limits adequate for catastrophic contamination events.
### **4. Noise Impacts**
As confirmed in Table 1 of the scoping document and prior Ecology PEISs, BESS operation "within 1,000 feet of people in quiet rural areas may affect nearby residents." The Klickitat County report notes that noise levels can exceed 70 dB at homes 100 feet away, far above the 45 dBA nighttime limit in most municipal codes.
**PEIS Requirement:** The PEIS must require that noise impacts be measured and mitigated at the property line of the nearest residence, not the facility fence line, with a focus on low-frequency noise and nighttime levels.
### **5. Alternatives Analysis — Technology and Siting**
Per SEPA, a robust alternatives analysis is required. This must include safer technologies and more appropriate locations.
**5A. Alternative Technologies**
The PEIS must evaluate non-lithium-ion and non-chemical energy storage alternatives that eliminate thermal runaway risk entirely. These include:
* **Flow Batteries:** Non-flammable, no explosion risk, longer duration, and use less environmentally damaging materials.
* **Sodium-ion Batteries:** A safer chemistry expected to be commercially available by 2028.
* **Mechanical Energy Storage:** Technologies like Pumped Hydro Storage, gravity-based systems, and Compressed Air Energy Storage (CAES), which the Southwest Research Institute notes are "robust alternatives to electro-chemical battery storage."
**PEIS Requirement:** The PEIS must analyze each battery chemistry separately, as their failure modes, toxic byproducts, and mitigation requirements differ significantly.
**5B. Alternative Siting**
State and local policies mandate the protection of environmental and community health.
* **RCW 80.50.010:** Requires that energy facilities "produce minimal adverse effects on the environment."
* **City of Snoqualmie Comprehensive Plan (Snoqualmie 2044):** Sets a goal to ensure "potential hazards to citizen health, welfare and property are minimized" and prioritizes "preservation of surface and groundwater quality, air quality." The plan recognizes the area's natural setting as one of its "most precious, assets."
If energy storage is deemed necessary, it must be sited in locations that do not externalize risk onto residential communities.
**PEIS Requirement:** The PEIS must identify and prioritize alternative sites such as industrial zones, brownfields, or other previously disturbed lands with robust emergency infrastructure, adequate water supply, multiple evacuation routes, and no proximity to sensitive receptors.
### **6. SEPA Legal Requirements**
Under RCW 43.21C.030(2)(c), an EIS is required for any major action with a "probable significant, adverse environmental impact." As established in *PT Air Watchers v. Department of Ecology*, SEPA requires "actual consideration of environmental factors" based on "information reasonably sufficient to evaluate the environmental impact." Furthermore, as held in *Columbia Riverkeeper v. Port of Vancouver USA*, project design must "benefit from information revealed by environmental review." A PEIS that pre-ordains BESS as safe or suitable for semi-rural siting would violate these core SEPA principles.
**PEIS Requirement:** The PEIS must provide a transparent, impartial discussion of all significant environmental impacts and reasonable alternatives, including the No Action Alternative. It must analyze direct, indirect, and cumulative impacts.
### **7. Necessity and Interests Served**
The PEIS must not accept the necessity of utility-scale lithium-ion BESS as a given. Washington's clean energy goals can be met "using a variety of clean energy resources," as the scoping document states. These goals do not override SEPA's mandate for environmental protection.
**PEIS Requirement:** The PEIS must critically evaluate who bears the risk versus who receives the benefit of these facilities. Siting industrial hazards in rural communities to serve urban load centers is a classic environmental justice problem that must be analyzed.
### **8. Specific Recommendations for the PEIS Scope**
Based on the foregoing analysis, the PEIS must:
1. **Define "suitable" areas by safety criteria first**—prohibiting siting near homes, schools, hospitals, drinking-water wells, the wildland-urban interface, seismic hazard zones, floodplains, and communities with limited evacuation routes. Proximity to infrastructure must be a secondary factor.
2. **Analyze each battery chemistry separately**, including failure modes and required mitigation.
3. **Model smoke dispersion from thermal runaway fires** under adverse conditions like temperature inversions.
4. **Analyze contaminated fire-suppression water pathways** to groundwater, private wells, and streams.
5. **Require UL 9540A testing and compliance with the current edition of NFPA 855** as a minimum standard.
6. **Recommend developer-funded emergency-response plans, training, and equipment** for local fire districts before operation.
7. **Require facility-specific emergency and evacuation plans** as a condition of any permit.
8. **Recommend enforceable nighttime noise limits** measured at the nearest residence.
9. **Require ongoing monitoring, cleanup guarantees, decommissioning bonds, and pollution liability insurance** with limits sufficient for a catastrophic event.
10. **Analyze earthquakes as common-cause failure scenarios.**
11. **Identify which impacts cannot be mitigated below a level of significance** and state this plainly.
12. **Evaluate non-lithium and non-chemical energy storage alternatives.**
13. **Establish minimum, scaled setbacks** (based on MWh) from homes, schools, hospitals, wells, floodplains, and fish-bearing streams.
14. **Require the use of independent safety experts** with no financial ties to BESS developers for all reviews.
15. **State that local governments may require stronger protections** than state minimums—state standards must be a floor, not a ceiling.
### **Conclusion**
The siting of utility-scale BESS facilities represents a new and significant environmental threat to Washington communities. I respectfully request that Ecology treat proximity to residents, farms, schools, and sensitive ecosystems as a defining condition of its analysis. The Draft PEIS must state plainly which of the severe impacts outlined above cannot be mitigated below a level of significance. This PEIS should establish a protective framework for Washington residents, not become a tool for accelerating BESS permitting at the expense of the communities asked to live beside these hazardous facilities.
Please include this comment in the official scoping record for the BESS PEIS.
Sincerely,
_________________________
Jacqueline Evans
MSN,CRNA, ARNP
36515 SE 56th St
Fall City, WA 98024↓
Clean Energy Coordination
Washington State Department of Ecology
PO Box 47709
Olympia, WA 98504-4709
**Re: Scoping Comments on the Battery Energy Storage System Facilities Programmatic Environmental Impact Statement (Publication 26-...↓06-017)**
Dear Clean Energy Coordination Team,
The rapid proliferation of utility-scale lithium-ion BESS proposals necessitates a rigorous, impartial, and scientifically grounded analysis of the significant adverse environmental impacts these facilities pose, particularly when sited near sensitive receptors.
This PEIS is especially critical in light of the proposed Cascadia Ridge Resiliency Energy Storage project by Jupiter Power LLC, a Texas-based company. This project would place an approximately 130 MW utility-scale lithium-ion BESS on a ~45-acre parcel of unincorporated King County land south of Fisher Creek Park, directly adjacent to the City of Snoqualmie and in close proximity to Cascade View Elementary School, residential neighborhoods, and agricultural lands. Jupiter Power has announced its intention to seek approval through the state Energy Facility Site Evaluation Council (EFSEC), bypassing local King County land use authority and underscoring the vital importance of robust statewide standards established by this PEIS.
Local concerns are already significant. The Snoqualmie Valley School District Board of Directors has formally called for an expanded environmental review of the Cascadia Ridge project, citing profound concerns for student safety and emergency preparedness. These concerns are echoed in Ecology's own scoping document, which acknowledges that stand-alone BESS "could be sited in a variety of locations," including near cities—a stark contrast to the previous solar and wind PEISs, which studied facilities "not likely to be located in or near cities." The scoping document rightly identifies public concerns raised about "adequate training and equipment for local responders, the difficulty of extinguishing fires, risks of hazardous air emissions, impacts to water and fish, and cleanup."
This letter outlines critical environmental, health, and safety factors that must be comprehensively evaluated in the PEIS.
### **1. Thermal Runaway Fire Risks and Toxic Contamination**
Lithium-ion BESS facilities present a unique and severe fire risk profile characterized by thermal runaway—a self-propagating, exothermic chain reaction where internal heat generation exceeds dissipation, causing cascading cell failure. Once initiated, this "domino effect" can spread to adjacent cells and modules, often resulting in intense, high-temperature fires that can burn for days and resist conventional extinguishment methods.
**1A. Fire Behavior and Toxic Gas Emissions**
The Klickitat County Utility-Scale BESS Report (May 2025) correctly summarizes the danger: "Fumes from a BESS fire contain hazardous chemicals that are toxic and dangerous resulting in necessary evacuation procedures for the surrounding neighborhood... Potentially hazardous chemicals released during the fire can pollute the water used to fight it and contaminate the surrounding soil or groundwater as it absorbs the runoff."
A primary chemical of concern is hydrogen fluoride (HF), a highly toxic gas. According to a Massachusetts state toxicology report, "The release of hydrogen fluoride from a Li-ion battery fire can therefore be a severe risk..." Upon contact with moisture in the eyes, skin, or lungs, HF forms hydrofluoric acid, an extremely corrosive substance that can cause deep tissue burns, bone damage, systemic toxicity (hypocalcemia), cardiac arrhythmia, and death. Civilians, and particularly children at nearby schools, have no protective equipment against such an exposure. The 2024 Otay Mesa fire in San Diego, which burned for 11 days, serves as a grim example; Cal Fire reported that lethal amounts of hydrogen cyanide were detected in the air within three hours of ignition.
**PEIS Requirement:** The PEIS must model the atmospheric dispersion of toxic gases—including hydrogen fluoride, hydrogen cyanide, and heavy metal particulates—from a catastrophic thermal runaway fire. These models must account for worst-case meteorological conditions, such as the temperature inversions common in the Snoqualmie Valley, which trap pollutants near ground level and can significantly expand the area of public health impact.
**1B. Soil and Groundwater Contamination from Firefighting Runoff**
The aftermath of a BESS fire presents a significant environmental contamination risk. Recent scientific evidence from the January 2025 Moss Landing BESS fire in California confirms this threat. Researchers from Moss Landing Marine Laboratories detected elevated levels of nickel, cobalt, and manganese in Elkhorn Slough soils following the fire. Their study estimated that approximately 25 metric tons (55,000 pounds) of heavy metals were deposited across roughly half a square mile of wetland. Critically, while surface concentrations dropped after rain events washed the toxic dust away, the researchers concluded that "the metals did not disappear," implying migration into the broader ecosystem. A separate study by the University of California Agriculture and Natural Resources evaluated the deposition of cobalt, copper, nickel, and manganese in agricultural fields, underscoring the direct threat to food production.
The Snoqualmie area's hydrogeology makes it exceptionally vulnerable. The area has two distinct aquifer systems: a shallow, unconfined aquifer in the Tokul Creek alluvial fan at depths of less than 35 feet, and a deeper aquifer at 70-170 feet. Many residents in the area rely on private wells for their drinking water.
**PEIS Requirement:** The PEIS must rigorously analyze the contaminant transport pathways of fire-suppression water and dissolved heavy metals from a BESS site to local groundwater, private wells, and fish-bearing streams. This analysis must account for local soil permeability, infiltration rates, and aquifer characteristics.
**1C. Air Quality Impacts**
The Snoqualmie Comprehensive Plan notes that "Snoqualmie is relatively free from air pollution" due to its rural setting. A BESS fire would represent an acute and catastrophic degradation of this air quality baseline, releasing a toxic plume of particulates and hazardous gases into the community.
**PEIS Requirement:** The PEIS must analyze how a BESS fire would degrade local air quality, particularly under valley inversion conditions that concentrate pollutants.
**1D. Failure Rate Data Limitations**
Industry assurances of BESS safety often rely on flawed and incomplete data. As documented in NIST Technical Note 2365 (March 2026), "Understanding the Risk of Lithium-Ion Battery Fires," the primary incident databases (UL, Tesla, EPRI) are "built on a deeply flawed foundation" because they are compiled from media reports and other public documents rather than systematic, mandatory incident reporting. The EPRI BESS Failure Incident Database methodology explicitly states this reliance on public sources. Furthermore, 72 of the 164 incidents in the EPRI database lack a MWh value, the key parameter for calculating a meaningful failure rate based on stored energy (GWh), not simply power flow (GW).
**PEIS Requirement:** The PEIS must reject reliance on industry-funded or media-derived incident data. It must disclose the funding source of all datasets used, demand independent safety data, and require as mitigation compliance with the most recent safety standards (e.g., UL 9540A, NFPA 855), regardless of state adoption status.
### **2. Siting, Proximity, and Compounded Hazards**
The core issue is that BESS facilities are industrial-scale chemical installations with inherent catastrophic failure modes, yet they are being proposed in and adjacent to residential, recreational, agricultural, and environmentally sensitive areas.
**2A. Proximity to Sensitive Receptors**
The proposed Cascadia Ridge site is a textbook example of inappropriate siting, located near Cascade View Elementary School, established residential neighborhoods (Snoqualmie Ridge), parks (Fisher Creek Park), and rural farms. The Washington State Department of Commerce's own *Energy Safety Resources* guide advises local governments to "Set minimum distances between a facility and nearby homes, schools, parks, waterways and property lines."
Proximity to a substation should not be the primary determinant of site suitability. While Ecology's scoping document notes it may consider proximity to existing infrastructure, this logic is dangerously flawed. In many Washington communities, that infrastructure is co-located with homes, schools, and water supplies.
**PEIS Requirement:** Suitability must be defined by safety criteria first. The PEIS must establish a framework that prioritizes human health and environmental safety over grid convenience, with enforceable, scaled setbacks.
**2B. Critical Areas and Aquifer Protection**
Local and county regulations explicitly protect the water resources threatened by the Cascadia Ridge proposal.
* **City of Snoqualmie Sensitive Areas Ordinance (SMC 19.12):** Defines a "Critical aquifer recharge area" as a source of drinking water with "no feasible alternative source" that is "susceptible to contamination from activities on the surface" due to "high infiltration rates."
* **Snoqualmie Comprehensive Plan:** Warns, "Once ground water is contaminated it is difficult, costly and sometimes impossible to restore. Groundwater resources must be protected from contamination..."
* **King County Code (KCC):** Restricts building in Critical Areas "to protect public health and safety, and to promote environmental health." The county defines Critical Aquifer Recharge Areas as those "susceptible to groundwater contamination."
**PEIS Requirement:** The PEIS must explicitly screen out Critical Aquifer Recharge Areas, areas dependent on private wells, floodplains, and seismic hazard zones from the geographic scope of "suitable" BESS sites.
**2C. Seismic Hazards**
The Snoqualmie Comprehensive Plan states, "Most of the upper Snoqualmie Valley... is a seismic hazard area," with saturated sandy soils on the Snoqualmie River floodplain that may be "susceptible to liquefaction." An earthquake is a critical initiating event that is not captured by standard operational failure rates. A seismic event could damage multiple battery enclosures simultaneously while disabling the grid, cooling systems, monitoring equipment, and fire suppression systems. This represents a common-cause failure scenario where emergency crews would be overwhelmed and access routes compromised.
**PEIS Requirement:** The PEIS must analyze earthquakes as a common-cause failure scenario, evaluating the simultaneous failure of containment, cooling, and suppression systems, as well as the impairment of emergency response.
**2D. Flooding**
The Snoqualmie River experiences the largest peak flows of any river in King County. Flooding could compromise containment systems, mobilize and spread contaminated runoff across a wide area, and render emergency response impossible.
**2E. Evacuation Capacity**
The Snoqualmie Ridge community has notoriously limited access routes. The landslide on December 10, 2025, that closed eastbound I-90 demonstrated how a single event can paralyze the local road network for hours.
**PEIS Requirement:** The PEIS must evaluate evacuation capacity as a critical aspect of public health and safety. It should require modeled evacuation time estimates for surrounding populations and recommend against siting BESS where a timely evacuation cannot be assured.
### **3. Insurance, Financial Assurance, and Liability Gaps**
A significant policy gap exists regarding financial responsibility for a catastrophic BESS incident. Washington's battery stewardship law (Chapter 70A.555 RCW) explicitly excludes BESS batteries, leaving no dedicated program for their end-of-life management or post-incident cleanup. There are currently no specific BESS insurance, cleanup bond, or decommissioning financial assurance requirements in Washington state law.
**PEIS Requirement:** The PEIS must analyze the profound question of liability: Who is responsible for environmental cleanup after a fire? What insurance limits are adequate for a multi-week fire and widespread contamination event? What happens if the operator is a limited liability entity that declares bankruptcy, leaving local communities and property owners to bear the cost? The PEIS should recommend mandatory, robust financial assurance requirements, including:
* Developer-funded environmental monitoring programs.
* Cleanup guarantees and bonds funded *before* operation begins.
* Decommissioning bonds sufficient to cover full site restoration, including soil and groundwater remediation.
* Pollution liability insurance with limits adequate for catastrophic contamination events.
### **4. Noise Impacts**
As confirmed in Table 1 of the scoping document and prior Ecology PEISs, BESS operation "within 1,000 feet of people in quiet rural areas may affect nearby residents." The Klickitat County report notes that noise levels can exceed 70 dB at homes 100 feet away, far above the 45 dBA nighttime limit in most municipal codes.
**PEIS Requirement:** The PEIS must require that noise impacts be measured and mitigated at the property line of the nearest residence, not the facility fence line, with a focus on low-frequency noise and nighttime levels.
### **5. Alternatives Analysis — Technology and Siting**
Per SEPA, a robust alternatives analysis is required. This must include safer technologies and more appropriate locations.
**5A. Alternative Technologies**
The PEIS must evaluate non-lithium-ion and non-chemical energy storage alternatives that eliminate thermal runaway risk entirely. These include:
* **Flow Batteries:** Non-flammable, no explosion risk, longer duration, and use less environmentally damaging materials.
* **Sodium-ion Batteries:** A safer chemistry expected to be commercially available by 2028.
* **Mechanical Energy Storage:** Technologies like Pumped Hydro Storage, gravity-based systems, and Compressed Air Energy Storage (CAES), which the Southwest Research Institute notes are "robust alternatives to electro-chemical battery storage."
**PEIS Requirement:** The PEIS must analyze each battery chemistry separately, as their failure modes, toxic byproducts, and mitigation requirements differ significantly.
**5B. Alternative Siting**
State and local policies mandate the protection of environmental and community health.
* **RCW 80.50.010:** Requires that energy facilities "produce minimal adverse effects on the environment."
* **City of Snoqualmie Comprehensive Plan (Snoqualmie 2044):** Sets a goal to ensure "potential hazards to citizen health, welfare and property are minimized" and prioritizes "preservation of surface and groundwater quality, air quality." The plan recognizes the area's natural setting as one of its "most precious, assets."
If energy storage is deemed necessary, it must be sited in locations that do not externalize risk onto residential communities.
**PEIS Requirement:** The PEIS must identify and prioritize alternative sites such as industrial zones, brownfields, or other previously disturbed lands with robust emergency infrastructure, adequate water supply, multiple evacuation routes, and no proximity to sensitive receptors.
### **6. SEPA Legal Requirements**
Under RCW 43.21C.030(2)(c), an EIS is required for any major action with a "probable significant, adverse environmental impact." As established in *PT Air Watchers v. Department of Ecology*, SEPA requires "actual consideration of environmental factors" based on "information reasonably sufficient to evaluate the environmental impact." Furthermore, as held in *Columbia Riverkeeper v. Port of Vancouver USA*, project design must "benefit from information revealed by environmental review." A PEIS that pre-ordains BESS as safe or suitable for semi-rural siting would violate these core SEPA principles.
**PEIS Requirement:** The PEIS must provide a transparent, impartial discussion of all significant environmental impacts and reasonable alternatives, including the No Action Alternative. It must analyze direct, indirect, and cumulative impacts.
### **7. Necessity and Interests Served**
The PEIS must not accept the necessity of utility-scale lithium-ion BESS as a given. Washington's clean energy goals can be met "using a variety of clean energy resources," as the scoping document states. These goals do not override SEPA's mandate for environmental protection.
**PEIS Requirement:** The PEIS must critically evaluate who bears the risk versus who receives the benefit of these facilities. Siting industrial hazards in rural communities to serve urban load centers is a classic environmental justice problem that must be analyzed.
### **8. Specific Recommendations for the PEIS Scope**
Based on the foregoing analysis, the PEIS must:
1. **Define "suitable" areas by safety criteria first**—prohibiting siting near homes, schools, hospitals, drinking-water wells, the wildland-urban interface, seismic hazard zones, floodplains, and communities with limited evacuation routes. Proximity to infrastructure must be a secondary factor.
2. **Analyze each battery chemistry separately**, including failure modes and required mitigation.
3. **Model smoke dispersion from thermal runaway fires** under adverse conditions like temperature inversions.
4. **Analyze contaminated fire-suppression water pathways** to groundwater, private wells, and streams.
5. **Require UL 9540A testing and compliance with the current edition of NFPA 855** as a minimum standard.
6. **Recommend developer-funded emergency-response plans, training, and equipment** for local fire districts before operation.
7. **Require facility-specific emergency and evacuation plans** as a condition of any permit.
8. **Recommend enforceable nighttime noise limits** measured at the nearest residence.
9. **Require ongoing monitoring, cleanup guarantees, decommissioning bonds, and pollution liability insurance** with limits sufficient for a catastrophic event.
10. **Analyze earthquakes as common-cause failure scenarios.**
11. **Identify which impacts cannot be mitigated below a level of significance** and state this plainly.
12. **Evaluate non-lithium and non-chemical energy storage alternatives.**
13. **Establish minimum, scaled setbacks** (based on MWh) from homes, schools, hospitals, wells, floodplains, and fish-bearing streams.
14. **Require the use of independent safety experts** with no financial ties to BESS developers for all reviews.
15. **State that local governments may require stronger protections** than state minimums—state standards must be a floor, not a ceiling.
### **Conclusion**
The siting of utility-scale BESS facilities represents a new and significant environmental threat to Washington communities. I respectfully request that Ecology treat proximity to residents, farms, schools, and sensitive ecosystems as a defining condition of its analysis. The Draft PEIS must state plainly which of the severe impacts outlined above cannot be mitigated below a level of significance. This PEIS should establish a protective framework for Washington residents, not become a tool for accelerating BESS permitting at the expense of the communities asked to live beside these hazardous facilities.
Please include this comment in the official scoping record for the BESS PEIS.
Sincerely,
_________________________
Jacqueline Evans
MSN,CRNA, ARNP
36515 SE 56th St
Fall City, WA 98024↓
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To: Clean Energy Coordination, Washington State Department of Ecology
Re: Scoping Comments, Battery Energy Storage System Facilities Programmatic EIS (Publication 26-06-017)
Dear Clean Energy Coordination Team,
My name is Megan Brocco. I own proper...↓ty in the Fall City / Snoqualmie Valley area of unincorporated King County within the 2 mile radius of the proposed Cascadia Ridge Resiliency Energy Storage project.
That project would put an approximately 130 MW stand-alone lithium-ion battery facility on about 45 acres south of Fisher Creek Park. The site is next to Snoqualmie Ridge neighborhoods and about 0.7 miles from Cascade View Elementary. The developer, Jupiter Power LLC of Austin, Texas, is a merchant energy company. It has said it will seek state certification through the Energy Facility Site Evaluation Council (EFSEC), bypassing county permitting.
I support Washington's clean-energy goals. I oppose siting utility-scale lithium-ion BESS next to homes, schools, farms, private wells, and salmon-bearing waters. Project reviews like Cascadia Ridge will tier to this PEIS, so its scope will decide whether communities are protected or merely studied. Below I explain the evidence. At the end I list the specific studies I ask Ecology to include.
1. SEPA requires weighing severity, not just probability
Developers point to declining fire rates. The Electric Power Research Institute (EPRI) recorded 24 battery-facility fires worldwide in 2025. But under WAC 197-11-794, an impact can be significant even when its chance of occurring is low, if the result would be severe. A multi-day lithium-ion fire upwind of a school, a neighborhood, and an agricultural valley is that kind of impact. Where data are incomplete, WAC 197-11-080 requires Ecology to disclose the gap rather than fill it with industry assurances.
2. What a single battery container can release
Peer-reviewed testing (Larsson et al., Scientific Reports, 2017) measured 20 to 200 mg of hydrogen fluoride (HF) per watt-hour of battery capacity during lithium-ion fires. Applied to one typical 5 MWh enclosure, that is on the order of 100 to 1,000 kg of HF from a single container. For comparison, NIOSH's "immediately dangerous to life or health" level for HF is 30 ppm. Lithium-ion fires also release hydrogen cyanide, carbon monoxide, and metal-rich particulate.
Large BESS fires are commonly fought defensively. Responders protect nearby exposures and let the involved enclosure burn out. That means releasing the chemical inventory to the air is the expected outcome of a fire, not a remote contingency.
3. Moss Landing shows contamination is real and traceable
Vistra's 300 MW Moss Landing facility burned on January 16, 2025, forcing about 1,200 residents to evacuate. Researchers at San José State University's Moss Landing Marine Laboratories had baseline soil data from nearby Elkhorn Slough. After the fire, they found nickel, manganese, and cobalt nanoparticles in marsh soils at roughly 100 to 1,000 times prior levels. The nickel-to-cobalt ratio matched the batteries' manufacturing proportion, a chemical fingerprint tying the deposits to the fire (Scientific Reports, November 2025).
A separate agricultural soil survey near the site did not find statistically significant increases. That contrast is the lesson: contamination can be confirmed or ruled out only where a baseline exists. Most Snoqualmie Valley farms, gardens, and private wells have none.
4. Firewater, PFAS, and salmon
Fire-suppression water can carry dissolved metals, fluoride, electrolyte byproducts, and PFAS. Research has identified fluorinated PFAS compounds in some lithium-ion battery components (Guelfo et al., Nature Communications, 2024). Washington already restricts PFAS in firefighting foam (RCW 70A.400).
The Cascadia Ridge site drains toward Fisher Creek and the Snoqualmie River. Those waters support ESA-listed Chinook salmon, the prey base for endangered Southern Resident orcas. They are also of treaty and cultural significance to the Snoqualmie Tribe, which raised these same contamination pathways in its scoping comments.
5. Who pays for cleanup?
Off-site contamination would fall under the Model Toxics Control Act (MTCA, chapter 70A.305 RCW), and damaged batteries are likely dangerous waste (chapter 173-303 WAC). MTCA makes owners and operators strictly liable. That liability is only as good as the party's ability to pay.
BESS are typically held by single-project LLCs. King County Ordinance 19824 requires only $1 million in financial responsibility for thermal events, and only under certain conditions. That is a small fraction of the plausible cost of multi-day response, off-site soil and well remediation, crop and livestock losses, and long-term monitoring. If the project entity dissolves, the cost shifts to the public and the neighbors.
6. Response to Jupiter Power's scoping comments
Jupiter Power, the Cascadia Ridge developer, submitted its own scoping comments. Several of its requests would weaken this PEIS, and I ask Ecology to reject them.
"Analyze benefits, but skip site-specific impacts and mitigation." This is backwards. A programmatic EIS is the right place for siting screens, exclusion areas, and baseline mitigation (WAC 197-11-442). If benefits are counted, they must be demonstrated for each project and weighed against the full cost of failure borne by the host community.
"Battery chemistry makes little difference." Chemistry drives thermal-runaway likelihood, heat release, off-gas composition, and the metals deposited after a fire. Jupiter itself has reportedly contracted for up to 4.75 GWh of sodium-ion batteries.
"Do not limit capacity or duration." Jupiter describes projects of 100 to 400 MW with 4 to 8 or more hours of storage. Civil plans for Cascadia Ridge have reportedly shown a buildout far larger than the 130 MW presented to the public. Hazard scales with stored energy (MWh), not nameplate power (MW).
"Potential impacts may be misread as likely." Disclosing foreseeable impacts is SEPA's purpose. A presumption toward protective measures is appropriate when the risk falls on people who never agreed to it.
"Batteries displace fossil-fuel peaker plants." Storage can raise system emissions depending on what charges it and what it displaces (Hittinger and Azevedo, Environmental Science & Technology, 2015). About 10 to 15 percent of stored energy is lost each charge-discharge cycle. Washington's hydro-dominated grid differs from the grids where these benefits were studied.
"Jobs and tax revenue." Construction jobs are temporary, and operating facilities employ few permanent staff. Public costs must be counted against tax revenue.
"Use specialized fire consultants" and "rely on NFPA 855 and UL 9540." Expertise must be independent of developers and manufacturers. Fire codes govern spacing and testing. They do not evaluate off-site deposition, groundwater, food-chain exposure, or cleanup liability.
7. Emergency response capacity and land-use policy
King County Fire District 38, which has jurisdiction over the site, has formally opposed it, warning that a BESS fire could overwhelm the area's emergency resources. Eastside Fire & Rescue has stated it cannot confirm it is fully prepared for an incident of this scale. Battery facilities have exploded as well as burned:
Surprise, Arizona (2019): an explosion injured firefighters.
Beijing (2021): an explosion killed two firefighters.
Otay Mesa, California (2024): the Gateway fire burned for days and forced evacuations.
The valley's evacuation routes are few: Snoqualmie Parkway, SR 202, SR 18, and I-90.
State and county policy point the same way:
The Growth Management Act requires protection of rural character, critical areas, and groundwater (RCW 36.70A.070(5)), based on best available science (RCW 36.70A.172).
EFSEC's statute calls for energy facilities with minimal adverse effects on the environment and state waters (RCW 80.50.010).
King County protects the Snoqualmie Agricultural Production District and its aquifer recharge areas, yet allows BESS on nearly 97 percent of unincorporated land.
The City of Sumner, which is building a 200 MW BESS, independently recommended excluding critical areas, wellhead protection areas, municipal watersheds, and wildlife conservation areas.
Requested studies: what the PEIS should analyze
I respectfully ask Ecology to include the following in the scope of the PEIS.
Worst-case fire scenario. Analyze full involvement of one or more enclosures burning over several days, not only a single-module failure. Identify which impacts cannot be mitigated below significance, consistent with WAC 197-11-794.
Toxic plume dispersion modeling. Model HF, hydrogen cyanide, carbon monoxide, and metal particulate under nighttime temperature inversions and valley terrain. Report concentrations at the nearest homes, schools, farms, and parks, at distances of 0.5, 1, 2, and 5 miles. Compare results to NIOSH IDLH and Acute Exposure Guideline Level (AEGL) thresholds.
Deposition onto farms and the food chain. Analyze deposition of nickel, cobalt, manganese, and fluoride onto cropland, pasture, home gardens, and livestock forage. Analyze plant and animal uptake, using the Moss Landing findings as a reference case.
Baseline sampling. Recommend that project-level review require pre-construction baseline sampling of soils, surface water, and every private well within a defined radius, so harm can be detected and proven.
Firewater, PFAS, and groundwater pathways. Quantify suppression-water volumes and chemistry for a multi-day event, including PFAS from batteries and suppressants. Map pathways to shallow aquifers, Critical Aquifer Recharge Areas, wellhead protection zones, private wells, and fish-bearing streams. Size containment for a full-facility event.
Salmon, orca, and Tribal resources. Analyze downstream effects on ESA-listed Chinook, Southern Resident orcas, and Tribal treaty and cultural waters, in consultation with affected Tribes.
Cleanup cost and financial assurance. Estimate worst-case response and remediation costs from real incidents, including Moss Landing's multi-year cleanup. Compare those costs with current insurance and bonding requirements. Evaluate MTCA liability when the operator is a single-project LLC. Recommend financial assurance scaled to stored energy (MWh), backed by a solvent parent or escrow, surviving sale or bankruptcy, with a defined process to compensate affected residents and farmers.
Emergency response and evacuation capacity. Assess local fire, hazmat, hospital, and HF-antidote capacity, firefighting water supply, and modeled evacuation times for surrounding populations, including schools. Treat inadequate capacity as a factor that disqualifies a site, not a later permit condition.
Exclusion mapping and setbacks. Map areas where utility-scale lithium-ion BESS should not be sited:
agricultural production districts
critical aquifer recharge and wellhead areas
areas dependent on private wells
shorelands, wetlands, and stream buffers
floodplains and seismic, landslide, and liquefaction zones
wildland-urban interface
communities with constrained evacuation routes.
Recommend setbacks from homes, schools, parks, and wells based on plume modeling, scaled to MWh. Proximity to a substation must not count as suitability.
Chemistry-specific analysis. Analyze NMC, LFP, sodium-ion, iron-air, and flow batteries separately. Recommend that the chemistry and the specific product be fixed and disclosed before project review, with no later substitution.
Full buildout and cumulative impacts. Analyze the maximum energy a site can hold, including expansion and augmentation. Analyze clustering of facilities around substations and in single watersheds.
Need, beneficiaries, and net emissions. Require project reviews to identify the specific grid need, the offtaker, and the revenue source: reliability, market arbitrage, or new large loads such as data centers. Evaluate net emissions using Washington grid data rather than assumed peaker displacement.
Alternatives. Compare lower-risk alternatives under WAC 197-11-440(5):
industrial, brownfield, and previously disturbed sites
non-flammable or lower-hazard storage, including pumped hydro (such as the Goldendale project Ecology itself reviewed)
demand response, efficiency, distributed storage, and grid upgrades.
Independence of data. Disclose the funding source of every dataset and rely on reviewers with no financial ties to BESS developers or manufacturers.
Local authority and timing. State that the PEIS's protections are a floor, not a ceiling, for local governments. Share interim findings with EFSEC so projects like Cascadia Ridge are not approved before this analysis is complete.
Washington does not have to choose between clean energy and safe communities. I urge Ecology to use this PEIS to protect people, land, and water first. Please include this comment in the scoping record and notify me of the Draft PEIS.
Respectfully,
Megan Brocco
BS Environmental Engineering, Columbia University
36515 SE 56th St, Fall City, WA 98024
brocco.megan@gmail.com↓
Re: Scoping Comments, Battery Energy Storage System Facilities Programmatic EIS (Publication 26-06-017)
Dear Clean Energy Coordination Team,
My name is Megan Brocco. I own proper...↓ty in the Fall City / Snoqualmie Valley area of unincorporated King County within the 2 mile radius of the proposed Cascadia Ridge Resiliency Energy Storage project.
That project would put an approximately 130 MW stand-alone lithium-ion battery facility on about 45 acres south of Fisher Creek Park. The site is next to Snoqualmie Ridge neighborhoods and about 0.7 miles from Cascade View Elementary. The developer, Jupiter Power LLC of Austin, Texas, is a merchant energy company. It has said it will seek state certification through the Energy Facility Site Evaluation Council (EFSEC), bypassing county permitting.
I support Washington's clean-energy goals. I oppose siting utility-scale lithium-ion BESS next to homes, schools, farms, private wells, and salmon-bearing waters. Project reviews like Cascadia Ridge will tier to this PEIS, so its scope will decide whether communities are protected or merely studied. Below I explain the evidence. At the end I list the specific studies I ask Ecology to include.
1. SEPA requires weighing severity, not just probability
Developers point to declining fire rates. The Electric Power Research Institute (EPRI) recorded 24 battery-facility fires worldwide in 2025. But under WAC 197-11-794, an impact can be significant even when its chance of occurring is low, if the result would be severe. A multi-day lithium-ion fire upwind of a school, a neighborhood, and an agricultural valley is that kind of impact. Where data are incomplete, WAC 197-11-080 requires Ecology to disclose the gap rather than fill it with industry assurances.
2. What a single battery container can release
Peer-reviewed testing (Larsson et al., Scientific Reports, 2017) measured 20 to 200 mg of hydrogen fluoride (HF) per watt-hour of battery capacity during lithium-ion fires. Applied to one typical 5 MWh enclosure, that is on the order of 100 to 1,000 kg of HF from a single container. For comparison, NIOSH's "immediately dangerous to life or health" level for HF is 30 ppm. Lithium-ion fires also release hydrogen cyanide, carbon monoxide, and metal-rich particulate.
Large BESS fires are commonly fought defensively. Responders protect nearby exposures and let the involved enclosure burn out. That means releasing the chemical inventory to the air is the expected outcome of a fire, not a remote contingency.
3. Moss Landing shows contamination is real and traceable
Vistra's 300 MW Moss Landing facility burned on January 16, 2025, forcing about 1,200 residents to evacuate. Researchers at San José State University's Moss Landing Marine Laboratories had baseline soil data from nearby Elkhorn Slough. After the fire, they found nickel, manganese, and cobalt nanoparticles in marsh soils at roughly 100 to 1,000 times prior levels. The nickel-to-cobalt ratio matched the batteries' manufacturing proportion, a chemical fingerprint tying the deposits to the fire (Scientific Reports, November 2025).
A separate agricultural soil survey near the site did not find statistically significant increases. That contrast is the lesson: contamination can be confirmed or ruled out only where a baseline exists. Most Snoqualmie Valley farms, gardens, and private wells have none.
4. Firewater, PFAS, and salmon
Fire-suppression water can carry dissolved metals, fluoride, electrolyte byproducts, and PFAS. Research has identified fluorinated PFAS compounds in some lithium-ion battery components (Guelfo et al., Nature Communications, 2024). Washington already restricts PFAS in firefighting foam (RCW 70A.400).
The Cascadia Ridge site drains toward Fisher Creek and the Snoqualmie River. Those waters support ESA-listed Chinook salmon, the prey base for endangered Southern Resident orcas. They are also of treaty and cultural significance to the Snoqualmie Tribe, which raised these same contamination pathways in its scoping comments.
5. Who pays for cleanup?
Off-site contamination would fall under the Model Toxics Control Act (MTCA, chapter 70A.305 RCW), and damaged batteries are likely dangerous waste (chapter 173-303 WAC). MTCA makes owners and operators strictly liable. That liability is only as good as the party's ability to pay.
BESS are typically held by single-project LLCs. King County Ordinance 19824 requires only $1 million in financial responsibility for thermal events, and only under certain conditions. That is a small fraction of the plausible cost of multi-day response, off-site soil and well remediation, crop and livestock losses, and long-term monitoring. If the project entity dissolves, the cost shifts to the public and the neighbors.
6. Response to Jupiter Power's scoping comments
Jupiter Power, the Cascadia Ridge developer, submitted its own scoping comments. Several of its requests would weaken this PEIS, and I ask Ecology to reject them.
"Analyze benefits, but skip site-specific impacts and mitigation." This is backwards. A programmatic EIS is the right place for siting screens, exclusion areas, and baseline mitigation (WAC 197-11-442). If benefits are counted, they must be demonstrated for each project and weighed against the full cost of failure borne by the host community.
"Battery chemistry makes little difference." Chemistry drives thermal-runaway likelihood, heat release, off-gas composition, and the metals deposited after a fire. Jupiter itself has reportedly contracted for up to 4.75 GWh of sodium-ion batteries.
"Do not limit capacity or duration." Jupiter describes projects of 100 to 400 MW with 4 to 8 or more hours of storage. Civil plans for Cascadia Ridge have reportedly shown a buildout far larger than the 130 MW presented to the public. Hazard scales with stored energy (MWh), not nameplate power (MW).
"Potential impacts may be misread as likely." Disclosing foreseeable impacts is SEPA's purpose. A presumption toward protective measures is appropriate when the risk falls on people who never agreed to it.
"Batteries displace fossil-fuel peaker plants." Storage can raise system emissions depending on what charges it and what it displaces (Hittinger and Azevedo, Environmental Science & Technology, 2015). About 10 to 15 percent of stored energy is lost each charge-discharge cycle. Washington's hydro-dominated grid differs from the grids where these benefits were studied.
"Jobs and tax revenue." Construction jobs are temporary, and operating facilities employ few permanent staff. Public costs must be counted against tax revenue.
"Use specialized fire consultants" and "rely on NFPA 855 and UL 9540." Expertise must be independent of developers and manufacturers. Fire codes govern spacing and testing. They do not evaluate off-site deposition, groundwater, food-chain exposure, or cleanup liability.
7. Emergency response capacity and land-use policy
King County Fire District 38, which has jurisdiction over the site, has formally opposed it, warning that a BESS fire could overwhelm the area's emergency resources. Eastside Fire & Rescue has stated it cannot confirm it is fully prepared for an incident of this scale. Battery facilities have exploded as well as burned:
Surprise, Arizona (2019): an explosion injured firefighters.
Beijing (2021): an explosion killed two firefighters.
Otay Mesa, California (2024): the Gateway fire burned for days and forced evacuations.
The valley's evacuation routes are few: Snoqualmie Parkway, SR 202, SR 18, and I-90.
State and county policy point the same way:
The Growth Management Act requires protection of rural character, critical areas, and groundwater (RCW 36.70A.070(5)), based on best available science (RCW 36.70A.172).
EFSEC's statute calls for energy facilities with minimal adverse effects on the environment and state waters (RCW 80.50.010).
King County protects the Snoqualmie Agricultural Production District and its aquifer recharge areas, yet allows BESS on nearly 97 percent of unincorporated land.
The City of Sumner, which is building a 200 MW BESS, independently recommended excluding critical areas, wellhead protection areas, municipal watersheds, and wildlife conservation areas.
Requested studies: what the PEIS should analyze
I respectfully ask Ecology to include the following in the scope of the PEIS.
Worst-case fire scenario. Analyze full involvement of one or more enclosures burning over several days, not only a single-module failure. Identify which impacts cannot be mitigated below significance, consistent with WAC 197-11-794.
Toxic plume dispersion modeling. Model HF, hydrogen cyanide, carbon monoxide, and metal particulate under nighttime temperature inversions and valley terrain. Report concentrations at the nearest homes, schools, farms, and parks, at distances of 0.5, 1, 2, and 5 miles. Compare results to NIOSH IDLH and Acute Exposure Guideline Level (AEGL) thresholds.
Deposition onto farms and the food chain. Analyze deposition of nickel, cobalt, manganese, and fluoride onto cropland, pasture, home gardens, and livestock forage. Analyze plant and animal uptake, using the Moss Landing findings as a reference case.
Baseline sampling. Recommend that project-level review require pre-construction baseline sampling of soils, surface water, and every private well within a defined radius, so harm can be detected and proven.
Firewater, PFAS, and groundwater pathways. Quantify suppression-water volumes and chemistry for a multi-day event, including PFAS from batteries and suppressants. Map pathways to shallow aquifers, Critical Aquifer Recharge Areas, wellhead protection zones, private wells, and fish-bearing streams. Size containment for a full-facility event.
Salmon, orca, and Tribal resources. Analyze downstream effects on ESA-listed Chinook, Southern Resident orcas, and Tribal treaty and cultural waters, in consultation with affected Tribes.
Cleanup cost and financial assurance. Estimate worst-case response and remediation costs from real incidents, including Moss Landing's multi-year cleanup. Compare those costs with current insurance and bonding requirements. Evaluate MTCA liability when the operator is a single-project LLC. Recommend financial assurance scaled to stored energy (MWh), backed by a solvent parent or escrow, surviving sale or bankruptcy, with a defined process to compensate affected residents and farmers.
Emergency response and evacuation capacity. Assess local fire, hazmat, hospital, and HF-antidote capacity, firefighting water supply, and modeled evacuation times for surrounding populations, including schools. Treat inadequate capacity as a factor that disqualifies a site, not a later permit condition.
Exclusion mapping and setbacks. Map areas where utility-scale lithium-ion BESS should not be sited:
agricultural production districts
critical aquifer recharge and wellhead areas
areas dependent on private wells
shorelands, wetlands, and stream buffers
floodplains and seismic, landslide, and liquefaction zones
wildland-urban interface
communities with constrained evacuation routes.
Recommend setbacks from homes, schools, parks, and wells based on plume modeling, scaled to MWh. Proximity to a substation must not count as suitability.
Chemistry-specific analysis. Analyze NMC, LFP, sodium-ion, iron-air, and flow batteries separately. Recommend that the chemistry and the specific product be fixed and disclosed before project review, with no later substitution.
Full buildout and cumulative impacts. Analyze the maximum energy a site can hold, including expansion and augmentation. Analyze clustering of facilities around substations and in single watersheds.
Need, beneficiaries, and net emissions. Require project reviews to identify the specific grid need, the offtaker, and the revenue source: reliability, market arbitrage, or new large loads such as data centers. Evaluate net emissions using Washington grid data rather than assumed peaker displacement.
Alternatives. Compare lower-risk alternatives under WAC 197-11-440(5):
industrial, brownfield, and previously disturbed sites
non-flammable or lower-hazard storage, including pumped hydro (such as the Goldendale project Ecology itself reviewed)
demand response, efficiency, distributed storage, and grid upgrades.
Independence of data. Disclose the funding source of every dataset and rely on reviewers with no financial ties to BESS developers or manufacturers.
Local authority and timing. State that the PEIS's protections are a floor, not a ceiling, for local governments. Share interim findings with EFSEC so projects like Cascadia Ridge are not approved before this analysis is complete.
Washington does not have to choose between clean energy and safe communities. I urge Ecology to use this PEIS to protect people, land, and water first. Please include this comment in the scoping record and notify me of the Draft PEIS.
Respectfully,
Megan Brocco
BS Environmental Engineering, Columbia University
36515 SE 56th St, Fall City, WA 98024
brocco.megan@gmail.com↓
Attachments:
Focus on Proven Technology: Expanding the PEIS to include unproven, emerging battery chemistries (like solid-state or metal-air) would require vast amounts of speculative research, delaying the release of the PEIS. Ecology should focus exclusively on...↓ lithium-ion because it dominates the current market; future technologies can be addressed via supplemental reviews when they become commercially viable.
Protecting Local Environmental Oversight: Downplaying traditional environmental impacts in a programmatic document ignores cumulative regional risks. Establishing generalized mitigation measures is exactly what a PEIS is for—it creates a baseline of environmental protection. Deferring these concerns allows developers to isolate their impact analyses, potentially masking broader ecological damage.
SEPA's True Mandate: The primary purpose of a SEPA review is to identify and mitigate environmental degradation, not to serve as an economic justification for private development. Emphasizing tax revenues and job creation distracts from the core mandate of environmental protection and risks creating a biased, promotional document rather than an objective environmental analysis.↓
Protecting Local Environmental Oversight: Downplaying traditional environmental impacts in a programmatic document ignores cumulative regional risks. Establishing generalized mitigation measures is exactly what a PEIS is for—it creates a baseline of environmental protection. Deferring these concerns allows developers to isolate their impact analyses, potentially masking broader ecological damage.
SEPA's True Mandate: The primary purpose of a SEPA review is to identify and mitigate environmental degradation, not to serve as an economic justification for private development. Emphasizing tax revenues and job creation distracts from the core mandate of environmental protection and risks creating a biased, promotional document rather than an objective environmental analysis.↓
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Lawsuit Filed Against Texas-Based Vistra Corporation and Other Relevant Parties for Moss Landing Battery Plant Fire
https://www.cpmlegal.com/media/news/15206_2025-02-27_Solano_Moss_Landing_Complaint.pdf
https://neveragainmosslanding.org/wp-content/u...↓ploads/2025/06/Moss-Landing-Never-Again-MLNA.Power-Point5.5.2025.Revised.pdf
County of Monterey Board of Supervisors Meeting 1/21/25
https://www.youtube.com/watch?v=ESrtqvhvgFg
East Palestine Conflicts of Interest
Vistra at MOSS Landing and East Palestine used CTEH
https://time.com/6262343/east-palestine-train-toxic-cleanup-conflicts-of-interest/
Why BESS insurers are sweating transformers and contractor errors over battery fires
https://time.com/6262343/east-palestine-train-toxic-cleanup-conflicts-of-interest/
↓
https://www.cpmlegal.com/media/news/15206_2025-02-27_Solano_Moss_Landing_Complaint.pdf
https://neveragainmosslanding.org/wp-content/u...↓ploads/2025/06/Moss-Landing-Never-Again-MLNA.Power-Point5.5.2025.Revised.pdf
County of Monterey Board of Supervisors Meeting 1/21/25
https://www.youtube.com/watch?v=ESrtqvhvgFg
East Palestine Conflicts of Interest
Vistra at MOSS Landing and East Palestine used CTEH
https://time.com/6262343/east-palestine-train-toxic-cleanup-conflicts-of-interest/
Why BESS insurers are sweating transformers and contractor errors over battery fires
https://time.com/6262343/east-palestine-train-toxic-cleanup-conflicts-of-interest/
↓
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Absolutely not!!! The entire Chehalis River basin area is a critical and essential region for sustainable agriculture (you know, FOOD SOURCE).
ANY potentially damaging "development" must be dramatically slowed down.
ABSOLUTELY nobody wants this garb...↓age anywhere near this precious region.↓
ANY potentially damaging "development" must be dramatically slowed down.
ABSOLUTELY nobody wants this garb...↓age anywhere near this precious region.↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Nicole Caprice and I live in Snoqualmie. I am submitting a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery ene...↓rgy storage system facilities in Washington (Publication 26-06-017). A stand-alone BESS facility is proposed near where I live, and Ecology has said project-level reviews will tier to this PEIS.
1. The study should evaluate large stand-alone facilities as they are actually being proposed in Washington: rows of container-based lithium-ion units located near homes, schools, wetlands, and constrained road networks. It should cover the range of battery chemistries and the largest facility sizes in use, not only smaller installations, and analyze them as built to the code Washington has actually adopted. When assessing failure risk, I ask that the PEIS rely on independent safety data rather than industry assurances, disclose the funding source of every dataset, and identify the most recent safety standards as required mitigation.
2. Proximity to a substation or power line should not make a site "suitable." Ecology's scoping document says it may consider proximity to existing infrastructure, but in many towns that infrastructure sits next to homes, schools, and water supplies. I ask that the PEIS define suitability by safety criteria first: proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes. Closeness to the grid can then be a secondary factor.
3. It's important that the study model what a battery fire's smoke does to the people living, working, and visiting nearby. First responder training matters, but the scoping document does not appear to address the everyday people who would be exposed with no protective gear: children in nearby schools, patients in hospitals, and adults in nearby offices. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride), with dispersion modeling for inversion-prone valleys where limited evacuation routes make leaving harder; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
4. General descriptions of protections "at a high level" are not enough for a county to act on. I ask that the PEIS identify specific, permit-ready measures so cities and counties have clear standards: minimum setbacks from homes, schools, hospitals, and drinking-water wells, based on the study's own smoke and hazard modeling; UL 9540A test results and compliance with the current edition of NFPA 855 regardless of state adoption status; developer-funded emergency-response plans, training, and equipment for local fire districts before operation, maintained for the life of the facility; a facility-specific emergency and evacuation plan completed before permitting, covering nearby schools, hospitals, workplaces, and areas with limited evacuation routes; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and ongoing monitoring, funded cleanup guarantees, and decommissioning bonds, noting where comparable financial assurance requirements already apply to other energy facilities in Washington.
This is personal for my household. I live near the proposed Cascadia Ridge stand-alone BESS facility, and my children attend school near this proposed site.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Nicole Caprice
Snoqualmie↓
My name is Nicole Caprice and I live in Snoqualmie. I am submitting a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion battery ene...↓rgy storage system facilities in Washington (Publication 26-06-017). A stand-alone BESS facility is proposed near where I live, and Ecology has said project-level reviews will tier to this PEIS.
1. The study should evaluate large stand-alone facilities as they are actually being proposed in Washington: rows of container-based lithium-ion units located near homes, schools, wetlands, and constrained road networks. It should cover the range of battery chemistries and the largest facility sizes in use, not only smaller installations, and analyze them as built to the code Washington has actually adopted. When assessing failure risk, I ask that the PEIS rely on independent safety data rather than industry assurances, disclose the funding source of every dataset, and identify the most recent safety standards as required mitigation.
2. Proximity to a substation or power line should not make a site "suitable." Ecology's scoping document says it may consider proximity to existing infrastructure, but in many towns that infrastructure sits next to homes, schools, and water supplies. I ask that the PEIS define suitability by safety criteria first: proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes. Closeness to the grid can then be a secondary factor.
3. It's important that the study model what a battery fire's smoke does to the people living, working, and visiting nearby. First responder training matters, but the scoping document does not appear to address the everyday people who would be exposed with no protective gear: children in nearby schools, patients in hospitals, and adults in nearby offices. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride), with dispersion modeling for inversion-prone valleys where limited evacuation routes make leaving harder; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
4. General descriptions of protections "at a high level" are not enough for a county to act on. I ask that the PEIS identify specific, permit-ready measures so cities and counties have clear standards: minimum setbacks from homes, schools, hospitals, and drinking-water wells, based on the study's own smoke and hazard modeling; UL 9540A test results and compliance with the current edition of NFPA 855 regardless of state adoption status; developer-funded emergency-response plans, training, and equipment for local fire districts before operation, maintained for the life of the facility; a facility-specific emergency and evacuation plan completed before permitting, covering nearby schools, hospitals, workplaces, and areas with limited evacuation routes; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and ongoing monitoring, funded cleanup guarantees, and decommissioning bonds, noting where comparable financial assurance requirements already apply to other energy facilities in Washington.
This is personal for my household. I live near the proposed Cascadia Ridge stand-alone BESS facility, and my children attend school near this proposed site.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Nicole Caprice
Snoqualmie↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Valerie Berglund and I live at 6717 Elderberry Ave SE, Snoqualmie WA 98065, United States. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statemen...↓t for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. I ask that Ecology name specific mitigation lead agencies can adopt as permit conditions: real setbacks from homes, schools, and wells; UL 9540A testing and the current NFPA 855 edition; funded training and equipment for local responders before a facility operates; capture and disposal of fire-suppression water; nighttime noise limits measured at the nearest home; and decommissioning bonds.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia BESS in Snoqualmie project. My household drinking water comes from a private well. My household depends on The parkway , which is also an emergency route for everyone along it. I am a Im a small business owner that operates within the evacuation limits. My business is primarily outside. I am concerned, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Valerie Berglund
6717 Elderberry Ave SE, Snoqualmie WA 98065, United States↓
My name is Valerie Berglund and I live at 6717 Elderberry Ave SE, Snoqualmie WA 98065, United States. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statemen...↓t for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. I ask that Ecology name specific mitigation lead agencies can adopt as permit conditions: real setbacks from homes, schools, and wells; UL 9540A testing and the current NFPA 855 edition; funded training and equipment for local responders before a facility operates; capture and disposal of fire-suppression water; nighttime noise limits measured at the nearest home; and decommissioning bonds.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Cascadia BESS in Snoqualmie project. My household drinking water comes from a private well. My household depends on The parkway , which is also an emergency route for everyone along it. I am a Im a small business owner that operates within the evacuation limits. My business is primarily outside. I am concerned, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Valerie Berglund
6717 Elderberry Ave SE, Snoqualmie WA 98065, United States↓
No attachments
Electric Power Research Institute (EPRI) claims "The [Battery Energy Storage System] failure rate dropped by 99% from 2018 to 2025" This statement is frequently used to convince residents that BESS are safer than before, as BESS fails catastrophicall...↓y communities are placing moratoriums.
________________________________________________________
The following video explains how EPRI's Battery Energy Storage System Failure Incident Database is based on a deeply flawed foundation.
Understanding the Risk of Lithium-Ion Battery Fires
https://youtu.be/X9kZVvdVhjg?si=6svWw2X44n6DxV--
The video refers to a recent paper - NIST technical note 2365 published in March of 2026, the National Institute of Standards and Technology, a paper titled Understanding the risk of lithium-ion battery fires. Six researchers, eight different data sources, that concludes we have a lithium-ion battery fire problem that is significantly larger than what's being reported. And most of the data we've been relying on to understand it is built on a deeply flawed foundation. When NIST looked at the major data sources tracking lithium-ion battery fires, the UL database, the Tesla fire database, the battery energy storage system database, they found that they're all built on news reports. Somebody is scraping the headlines, they log the incident, and that becomes the data.
________________________________________________________
NIST TN 2365 — Understanding the Risk of Lithium-Ion Battery Fires:
https://doi.org/10.6028/NIST.TN.2365
______________________________________________________
Battery Energy Storage System Failure Incident Database
https://energystorage.epri.com/hub/public/en/failure-incident-database.html
"The failure rate dropped by 99% from 2018 to 2025"
"Database Methodology
The information in this database is gathered from media reports and other public documents, such as released
root cause analyses (RCA) or corporate press releases."
Link to download csv file of the failure incident database -
https://energystorage.epri.com/hub/public/Failure_Incident_Database_Stationary_Storage.csv
Analysis of failure data: 165 rows, 72 out of 164 incidents have no value for MWh, which is the key parameter used to calculate the failure rate. 32 incidents are "confidential". MOSS Landing does not show "explosion". 7/3/2013 in US, WA, Port Angeles has no information regarding chemistry, and omits the fact that it reignited the following week.
______________________________________________________________________-
The The hidden risk behind growing capacity.
GROW THE SAN DIEGO WAY . JP THEBERGE AND JOE ROWLEY . JUNE. 19, 2024
As battery energy storage systems (BESS) rapidly expand to support
renewable energy, new data and analysis reveals a concerning trend: while
failure rates appear to be improving, the actual risk of fires at individual
facilities might be considerably higher than the industry would like to reveal.
In fact, developers and industry lobbyists and spokespeople regularly state
that fires are "extremely rare." Let's examine the validity of that statement.
Tesla Megapack on fire at Victorian Big Battery, Australia. Image: Fire Rescue Victoria
The hidden risk behind growing capacity.
GROW THE SAN DIEGO WAY · JP THEBERGE AND JOE ROWLEY · JUNE. 19, 2024
As battery energy storage systems (BESS) rapidly expand to support renewable energy, new data and analysis reveals a concerning trend: while failure rates appear to be improving, the actual risk of fires at individual facilities might be considerably higher than the industry would like to reveal. In fact, developers and industry lobbyists and spokespeople regularly state that fires are "extremely rare." Let's examine the validity of that statement.
The industry has been promoting the idea that great strides in safety are being made and that despite a massive growth in deployments, failures have not increased as fast. Improvements certainly have been made. The industry has learned from past mistakes. But the statement that fires are "extremely rare" doesn't pass muster. EPRI (Electric Power Research Institute), the research arm of the power industry, keeps a database of failures (link). Their own data shows approximately 87 failures since the first utility scale BESS was installed less than thirteen years ago. The majority of these have happened since 2021, about one failure per month.
An important caveat to the EPRI failure data: their database mostly tracks fires that have received media attention so it understates the incidence of fires. Media coverage is an imperfect metric because the media often has other issues to cover that might preclude coverage of a fire, particularly in remote areas. Foreign media may or may or not place an emphasis on these events (and coverage in other languages typically does not always reach the US). So this metric produces an incomplete count of failures.
Statistical techniques downplay risk
EPRI has been circulating a chart that appears to show that BESS failures have gone down significantly in recent years, despite the explosion in capacity worldwide. We engaged a team of energy experts, researchers and statisticians to review their data and they found that the EPRI chart is misleading for a number of reasons. For one, the chart relies upon media coverage to track failures, so the failure rates it presents are understated.
The light blue curved field indicates cumulative deployed gigawatts (GW). It is a cumulative figure so it counts all the wattage that has been deployed since 2018. In 2023, there were around 52 total gigawatts of BESS facilities deployed worldwide (cumulative deployment, light blue, left axis). The dark blue bars indicate failures in each year. The bars are not cumulative. They show between 4 and 16 failures per year (failure incidents, in dark blue, left axis). And in fact they show that failures have been steadily rising since 2020. Then the chart uses a right axis scale to show failures per GW deployed per year as an orange line. The failures per GW in the early years of 2018 and 2019 were astronomical which makes the more recent data seem small, but is it? Here's the same chart using just the last four years of data which is when the industry really started to grow exponentially.
The rescaled chart shows an increase in failure rates (2020-21) followed by some improvement (2021-2023). These up-and-down variations might or might not be statistically significant, given the scant few years of data collected and weakness in the collection methodology. Taken as a whole, however, the risk of failure is still very much a concern. For example, the 2020-23 average is 0.55 failures per GW per year, which means that for every GW deployed, there would be a failure every 2 years or so.
Gigawatts (GW) are not the true measure of energy stored or facility size.
The biggest problem with EPRI's analysis is that gigawatts are a measure of energy flow, not of storage capacity. To understand how big a facility is (i.e., how much battery material is onsite) you need to know how much energy is stored which is measured in gigawatt-hours (GWh). Using water as an analogy, gigawatts (without hours) measure the flow rate of water coming out of a pipe. But it is gigawatt-hours that tells us the size of the storage tank (say, total number of gallons of water).
A facility capable of generating one gigawatt (GW) could contain one, two, three or even four gigawatt-hours (GWh) of storage. A four gigawatt-hour facility would require storing onsite, four times more batteries than a one gigawatt-hour (GWh) facility even though both might be rated one gigawatt (GW). It would have to have four times as much space to store batteries. And, logic dictates that whatever the failure rate is for a one GWh facility, it is four times higher for a four GWh facility as there are four times as many battery cells that can malfunction. So, the "h" in GWh is very important. There is no safety in numbers when it comes to lithium-ion battery storage facilities; the more batteries there are (as many as 6 million cells in a facility like Seguro), the more chances of fire.
At 1,280 MWh (or 1.28 GWh), Seguro would contain more than 5 times more batteries onsite than the 250 MWh Otay Mesa facility that burned in May 2004.
The bigger the facility, the more likely the failure.
If you use only the (understated) data provided by EPRI in their chart and in their database, you learn something quite interesting and intuitive. The chart provides us very specific numbers for the failure rate per GW (each year), which, when converted to GWh, shows us how many failures one should expect for a facility of any given size in GWh. This conversion yields an average failure rate over the last four years of 0.22 failures per GWh per year which means that for every GWh, there will be a failure about every 5 years. The below chart shows likely number of lifetime failures for different size facilities (blue columns) and average frequency of failures (orange line). The larger the facility (blue columns) the more failures, and the more frequently they are likely to occur (orange line).
The industry uses the EPRI chart to show that failure rates have improved over time, but if you do the simple math, they still pose a substantial risk. For example, a facility like Seguro would have 1,280 MWh (or 1.28 GWh) of batteries onsite. That translates to a 28% chance of having a fire each year or approximately one fire every three and a half years. Over its 60 year site lifespan, it is likely to have about 17 fire incidents. Click here to see the math explained in more detail. This provides another perspective to the data they have provided but provides little consolation to those who would be forced to live next door to such a facility.
EPRI chart graphic is missing data.
From 2020 to 2024, the EPRI chart shows 42 failures, but the latest updated table shown on their website shows 46 failures, so the total is about 10% lower than the actual data. A corrected chart would show four fires in 2020, twelve in 2021, fifteen in 2022 and fifteen in 2023. Our analysis uses this corrected failure count.
Failure data is not rigorous, and understated.
As mentioned above, the reliance on haphazard fire reporting from local media does not pass methodological muster. There isn't a system in place to track, document and chronicle battery energy storage fires so we have no choice but to rely on the imperfect EPRI database. This data is incomplete, and as a result, understates the failure rate. The projections are therefore a "best case scenario." The risk is likely higher than what EPRI suggests as well as our own analysis provided here. There are likely more facilities that have caught fire but for any number of reasons, did not receive media coverage. For example fires can happen at remote installations in areas that are not very populated or have no local media. Fires at facilities in foreign countries may get coverage in different languages which are less likely to be picked up in the US. And some countries, like China, are able to control their media to avoid raising doubts about an important export of theirs (they control 40% of the ESS market worldwide). But looking specifically at San Diego County, we know there are three large-scale facilities that are in operation. And, we know there have been three fires in the past four years, which contradicts the narrative that the risk is "extremely low."
Facility failures are a lagging indicator.
Despite the fact that some facility failures happen during the commissioning process (a time when systems are being installed and tested and systems are more vulnerable), the average time to failure from 2020 to 2023 has been 1.8 years (based on the EPRI database figures). What this means is that, for any given year, the failures that are reported in the EPRI database generally do not reflect failures contributed by facilities that have come online that year (and included in the cumulative gigawatt data in the EPRI graph). For example, the Otay Mesa facility that caught fire in May 2024 was almost four years old. That facility, however, was included in the total GW shown on the EPRI graph for 2021, 2022, and 2023. This lagging effect is another reason why the failure rates shown on the EPRI graph are understated.
We have no data on the failure rate of older facilities.
Because this industry is so new (the first utility scale facility was commissioned in 2012) and the vast majority of facilities have come online in the past 4 years, we have almost no data on facilities that are 5 or more years old. Aging facilities will have more maintenance issues and more problems related to aging lithium-ion battery cells. Research has shown that lithium-ion batteries become less stable as they age and are more prone to undergo thermal runaway at lower threshold temperatures compared to newer batteries. What will happen when billions of lithium-ion cells approach their end-of-life? Will we see more fire incidents? We don't know because we haven't gotten there yet.
Despite advancements and claims from an over-confident but profitable industry, the technology is nascent and the risk remains significant.
The battery energy storage industry is brand new and growing quickly; there is little in the way of land use regulations around the country that might properly mitigate the risk for communities. Counties and cities have been caught off-guard and lack the knowledge, staff expertise (and time) to assess these projects adequately and objectively. The industry has exploited this deficit and aggressively downplayed the risks, minimizing concerns by using jargon and misleading statistics and employing industry-friendly consultants who essentially wield their expertise as a tool to get projects quickly approved without pushback. It's time for us to stop, take a breath and objectively review the risks involved in these installations. That will enable decisions that are based, not on the profit-motive of an ambitious industry, but on independent facts, stakeholder input and review by all those who will be impacted by these types of projects.
________________________________________________________________
EPRI has been accused of green washing,
https://energyandpolicy.org/ameren-shareholders-reject-anti-greenwashing-proposal/
Evidence suggests Ameren goals are inconsistent with Paris Agreement
Ameren committed in 2023 to reduce its greenhouse-gas emissions by 60% by 2030 and 85% by 2040 compared with a 2005 baseline, and to reach net-zero emissions by 2045. Ameren's board noted to shareholders that it used studies by the Electric Power Research Institute (EPRI) to determine that its emissions reductions are proportional to the global emission reductions necessary to achieve the Paris Agreement's goal. EPRI is a membership organization of investor-owned utilities; about half of its revenue in 2023 was derived from dues paid by those companies, including Ameren, and its board of directors is composed of utility executives, including Ameren's, according to EPRI tax filings.
EPRI's published research has focused heavily on the uncertainty inherent in climate and emissions reduction models, and used it to cast doubt on whether it is even possible for utilities to set science-based targets. EPRI's emphasis on uncertainty could allow utilities to decrease carbon emissions very slowly, or even increase them, and argue that their goals are aligned with the Paris Agreement, by leaning on extreme outliers in climate and emissions models.
Utilities have frequently used EPRI's work to justify their target-setting.
EPRI's studies are an inappropriate tool for evaluating utility emissions, and differ widely from non-industry-affiliated assessments, Lander wrote.
__________________________________________________________________
https://energyandpolicy.org/utility-climate-policy/
For evidence that Duke's decarbonization is aligned with the Paris Agreement's goals, the company cited an analysis published by the Electric Power Research Institute (EPRI), a research organization funded by dues provided by electric utilities. But EPRI's paper on the topic cast doubt on whether it is even possible for utilities to set science-based targets and claimed that uncertainty about whether global climate targets are possible to achieve called into question the need for electric utilities to set their own goals.↓
________________________________________________________
The following video explains how EPRI's Battery Energy Storage System Failure Incident Database is based on a deeply flawed foundation.
Understanding the Risk of Lithium-Ion Battery Fires
https://youtu.be/X9kZVvdVhjg?si=6svWw2X44n6DxV--
The video refers to a recent paper - NIST technical note 2365 published in March of 2026, the National Institute of Standards and Technology, a paper titled Understanding the risk of lithium-ion battery fires. Six researchers, eight different data sources, that concludes we have a lithium-ion battery fire problem that is significantly larger than what's being reported. And most of the data we've been relying on to understand it is built on a deeply flawed foundation. When NIST looked at the major data sources tracking lithium-ion battery fires, the UL database, the Tesla fire database, the battery energy storage system database, they found that they're all built on news reports. Somebody is scraping the headlines, they log the incident, and that becomes the data.
________________________________________________________
NIST TN 2365 — Understanding the Risk of Lithium-Ion Battery Fires:
https://doi.org/10.6028/NIST.TN.2365
______________________________________________________
Battery Energy Storage System Failure Incident Database
https://energystorage.epri.com/hub/public/en/failure-incident-database.html
"The failure rate dropped by 99% from 2018 to 2025"
"Database Methodology
The information in this database is gathered from media reports and other public documents, such as released
root cause analyses (RCA) or corporate press releases."
Link to download csv file of the failure incident database -
https://energystorage.epri.com/hub/public/Failure_Incident_Database_Stationary_Storage.csv
Analysis of failure data: 165 rows, 72 out of 164 incidents have no value for MWh, which is the key parameter used to calculate the failure rate. 32 incidents are "confidential". MOSS Landing does not show "explosion". 7/3/2013 in US, WA, Port Angeles has no information regarding chemistry, and omits the fact that it reignited the following week.
______________________________________________________________________-
The The hidden risk behind growing capacity.
GROW THE SAN DIEGO WAY . JP THEBERGE AND JOE ROWLEY . JUNE. 19, 2024
As battery energy storage systems (BESS) rapidly expand to support
renewable energy, new data and analysis reveals a concerning trend: while
failure rates appear to be improving, the actual risk of fires at individual
facilities might be considerably higher than the industry would like to reveal.
In fact, developers and industry lobbyists and spokespeople regularly state
that fires are "extremely rare." Let's examine the validity of that statement.
Tesla Megapack on fire at Victorian Big Battery, Australia. Image: Fire Rescue Victoria
The hidden risk behind growing capacity.
GROW THE SAN DIEGO WAY · JP THEBERGE AND JOE ROWLEY · JUNE. 19, 2024
As battery energy storage systems (BESS) rapidly expand to support renewable energy, new data and analysis reveals a concerning trend: while failure rates appear to be improving, the actual risk of fires at individual facilities might be considerably higher than the industry would like to reveal. In fact, developers and industry lobbyists and spokespeople regularly state that fires are "extremely rare." Let's examine the validity of that statement.
The industry has been promoting the idea that great strides in safety are being made and that despite a massive growth in deployments, failures have not increased as fast. Improvements certainly have been made. The industry has learned from past mistakes. But the statement that fires are "extremely rare" doesn't pass muster. EPRI (Electric Power Research Institute), the research arm of the power industry, keeps a database of failures (link). Their own data shows approximately 87 failures since the first utility scale BESS was installed less than thirteen years ago. The majority of these have happened since 2021, about one failure per month.
An important caveat to the EPRI failure data: their database mostly tracks fires that have received media attention so it understates the incidence of fires. Media coverage is an imperfect metric because the media often has other issues to cover that might preclude coverage of a fire, particularly in remote areas. Foreign media may or may or not place an emphasis on these events (and coverage in other languages typically does not always reach the US). So this metric produces an incomplete count of failures.
Statistical techniques downplay risk
EPRI has been circulating a chart that appears to show that BESS failures have gone down significantly in recent years, despite the explosion in capacity worldwide. We engaged a team of energy experts, researchers and statisticians to review their data and they found that the EPRI chart is misleading for a number of reasons. For one, the chart relies upon media coverage to track failures, so the failure rates it presents are understated.
The light blue curved field indicates cumulative deployed gigawatts (GW). It is a cumulative figure so it counts all the wattage that has been deployed since 2018. In 2023, there were around 52 total gigawatts of BESS facilities deployed worldwide (cumulative deployment, light blue, left axis). The dark blue bars indicate failures in each year. The bars are not cumulative. They show between 4 and 16 failures per year (failure incidents, in dark blue, left axis). And in fact they show that failures have been steadily rising since 2020. Then the chart uses a right axis scale to show failures per GW deployed per year as an orange line. The failures per GW in the early years of 2018 and 2019 were astronomical which makes the more recent data seem small, but is it? Here's the same chart using just the last four years of data which is when the industry really started to grow exponentially.
The rescaled chart shows an increase in failure rates (2020-21) followed by some improvement (2021-2023). These up-and-down variations might or might not be statistically significant, given the scant few years of data collected and weakness in the collection methodology. Taken as a whole, however, the risk of failure is still very much a concern. For example, the 2020-23 average is 0.55 failures per GW per year, which means that for every GW deployed, there would be a failure every 2 years or so.
Gigawatts (GW) are not the true measure of energy stored or facility size.
The biggest problem with EPRI's analysis is that gigawatts are a measure of energy flow, not of storage capacity. To understand how big a facility is (i.e., how much battery material is onsite) you need to know how much energy is stored which is measured in gigawatt-hours (GWh). Using water as an analogy, gigawatts (without hours) measure the flow rate of water coming out of a pipe. But it is gigawatt-hours that tells us the size of the storage tank (say, total number of gallons of water).
A facility capable of generating one gigawatt (GW) could contain one, two, three or even four gigawatt-hours (GWh) of storage. A four gigawatt-hour facility would require storing onsite, four times more batteries than a one gigawatt-hour (GWh) facility even though both might be rated one gigawatt (GW). It would have to have four times as much space to store batteries. And, logic dictates that whatever the failure rate is for a one GWh facility, it is four times higher for a four GWh facility as there are four times as many battery cells that can malfunction. So, the "h" in GWh is very important. There is no safety in numbers when it comes to lithium-ion battery storage facilities; the more batteries there are (as many as 6 million cells in a facility like Seguro), the more chances of fire.
At 1,280 MWh (or 1.28 GWh), Seguro would contain more than 5 times more batteries onsite than the 250 MWh Otay Mesa facility that burned in May 2004.
The bigger the facility, the more likely the failure.
If you use only the (understated) data provided by EPRI in their chart and in their database, you learn something quite interesting and intuitive. The chart provides us very specific numbers for the failure rate per GW (each year), which, when converted to GWh, shows us how many failures one should expect for a facility of any given size in GWh. This conversion yields an average failure rate over the last four years of 0.22 failures per GWh per year which means that for every GWh, there will be a failure about every 5 years. The below chart shows likely number of lifetime failures for different size facilities (blue columns) and average frequency of failures (orange line). The larger the facility (blue columns) the more failures, and the more frequently they are likely to occur (orange line).
The industry uses the EPRI chart to show that failure rates have improved over time, but if you do the simple math, they still pose a substantial risk. For example, a facility like Seguro would have 1,280 MWh (or 1.28 GWh) of batteries onsite. That translates to a 28% chance of having a fire each year or approximately one fire every three and a half years. Over its 60 year site lifespan, it is likely to have about 17 fire incidents. Click here to see the math explained in more detail. This provides another perspective to the data they have provided but provides little consolation to those who would be forced to live next door to such a facility.
EPRI chart graphic is missing data.
From 2020 to 2024, the EPRI chart shows 42 failures, but the latest updated table shown on their website shows 46 failures, so the total is about 10% lower than the actual data. A corrected chart would show four fires in 2020, twelve in 2021, fifteen in 2022 and fifteen in 2023. Our analysis uses this corrected failure count.
Failure data is not rigorous, and understated.
As mentioned above, the reliance on haphazard fire reporting from local media does not pass methodological muster. There isn't a system in place to track, document and chronicle battery energy storage fires so we have no choice but to rely on the imperfect EPRI database. This data is incomplete, and as a result, understates the failure rate. The projections are therefore a "best case scenario." The risk is likely higher than what EPRI suggests as well as our own analysis provided here. There are likely more facilities that have caught fire but for any number of reasons, did not receive media coverage. For example fires can happen at remote installations in areas that are not very populated or have no local media. Fires at facilities in foreign countries may get coverage in different languages which are less likely to be picked up in the US. And some countries, like China, are able to control their media to avoid raising doubts about an important export of theirs (they control 40% of the ESS market worldwide). But looking specifically at San Diego County, we know there are three large-scale facilities that are in operation. And, we know there have been three fires in the past four years, which contradicts the narrative that the risk is "extremely low."
Facility failures are a lagging indicator.
Despite the fact that some facility failures happen during the commissioning process (a time when systems are being installed and tested and systems are more vulnerable), the average time to failure from 2020 to 2023 has been 1.8 years (based on the EPRI database figures). What this means is that, for any given year, the failures that are reported in the EPRI database generally do not reflect failures contributed by facilities that have come online that year (and included in the cumulative gigawatt data in the EPRI graph). For example, the Otay Mesa facility that caught fire in May 2024 was almost four years old. That facility, however, was included in the total GW shown on the EPRI graph for 2021, 2022, and 2023. This lagging effect is another reason why the failure rates shown on the EPRI graph are understated.
We have no data on the failure rate of older facilities.
Because this industry is so new (the first utility scale facility was commissioned in 2012) and the vast majority of facilities have come online in the past 4 years, we have almost no data on facilities that are 5 or more years old. Aging facilities will have more maintenance issues and more problems related to aging lithium-ion battery cells. Research has shown that lithium-ion batteries become less stable as they age and are more prone to undergo thermal runaway at lower threshold temperatures compared to newer batteries. What will happen when billions of lithium-ion cells approach their end-of-life? Will we see more fire incidents? We don't know because we haven't gotten there yet.
Despite advancements and claims from an over-confident but profitable industry, the technology is nascent and the risk remains significant.
The battery energy storage industry is brand new and growing quickly; there is little in the way of land use regulations around the country that might properly mitigate the risk for communities. Counties and cities have been caught off-guard and lack the knowledge, staff expertise (and time) to assess these projects adequately and objectively. The industry has exploited this deficit and aggressively downplayed the risks, minimizing concerns by using jargon and misleading statistics and employing industry-friendly consultants who essentially wield their expertise as a tool to get projects quickly approved without pushback. It's time for us to stop, take a breath and objectively review the risks involved in these installations. That will enable decisions that are based, not on the profit-motive of an ambitious industry, but on independent facts, stakeholder input and review by all those who will be impacted by these types of projects.
________________________________________________________________
EPRI has been accused of green washing,
https://energyandpolicy.org/ameren-shareholders-reject-anti-greenwashing-proposal/
Evidence suggests Ameren goals are inconsistent with Paris Agreement
Ameren committed in 2023 to reduce its greenhouse-gas emissions by 60% by 2030 and 85% by 2040 compared with a 2005 baseline, and to reach net-zero emissions by 2045. Ameren's board noted to shareholders that it used studies by the Electric Power Research Institute (EPRI) to determine that its emissions reductions are proportional to the global emission reductions necessary to achieve the Paris Agreement's goal. EPRI is a membership organization of investor-owned utilities; about half of its revenue in 2023 was derived from dues paid by those companies, including Ameren, and its board of directors is composed of utility executives, including Ameren's, according to EPRI tax filings.
EPRI's published research has focused heavily on the uncertainty inherent in climate and emissions reduction models, and used it to cast doubt on whether it is even possible for utilities to set science-based targets. EPRI's emphasis on uncertainty could allow utilities to decrease carbon emissions very slowly, or even increase them, and argue that their goals are aligned with the Paris Agreement, by leaning on extreme outliers in climate and emissions models.
Utilities have frequently used EPRI's work to justify their target-setting.
EPRI's studies are an inappropriate tool for evaluating utility emissions, and differ widely from non-industry-affiliated assessments, Lander wrote.
__________________________________________________________________
https://energyandpolicy.org/utility-climate-policy/
For evidence that Duke's decarbonization is aligned with the Paris Agreement's goals, the company cited an analysis published by the Electric Power Research Institute (EPRI), a research organization funded by dues provided by electric utilities. But EPRI's paper on the topic cast doubt on whether it is even possible for utilities to set science-based targets and claimed that uncertainty about whether global climate targets are possible to achieve called into question the need for electric utilities to set their own goals.↓
BESS systems should not be near schools, neighborhood, communities...anywhere near a population. The risks due to the noise and fire is too extreme. Our children are our future...we need to protect them. There are many non-populated areas where BESS...↓ are better placed.↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Barbara Anderson and I live in Snohomish, Washington. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lit...↓hium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley where a lot of my family lives, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give counties nothing to write into a permit and provide little protection for communities.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, drinking-water wells, and rivers that are proven to be safe for the surrounding community, not just general guidelines.
The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk.
The study should detail what it would take to reduce wildfire and fire-response harms, including funded training and equipment for local responders before a facility opens, since Ecology's earlier studies could not say whether they can be reduced enough.
If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable.
The study should recommend developer-funded monitoring, cleanup guarantees, and decommissioning bonds, as state rules already require these for other energy facilities.
The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record.
Sincerely,
Barbara Anderson
Snohomish, Washington↓
My name is Barbara Anderson and I live in Snohomish, Washington. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lit...↓hium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley where a lot of my family lives, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give counties nothing to write into a permit and provide little protection for communities.
The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, drinking-water wells, and rivers that are proven to be safe for the surrounding community, not just general guidelines.
The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk.
The study should detail what it would take to reduce wildfire and fire-response harms, including funded training and equipment for local responders before a facility opens, since Ecology's earlier studies could not say whether they can be reduced enough.
If harm from a BESS facility cannot be fixed, such as a fire that a small rural district cannot contain, the study should say so plainly and label it unavoidable.
The study should recommend developer-funded monitoring, cleanup guarantees, and decommissioning bonds, as state rules already require these for other energy facilities.
The study should state that local governments may require stronger protections than the state minimum. State standards should be a floor, not a ceiling.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record.
Sincerely,
Barbara Anderson
Snohomish, Washington↓
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No city willingly allows these systems into place, but have the infrastructure to support if something goes wrong. These bess sites are targeted toward rural areas that can't afford the infrastructure to fight if something goes wrong, and don't hav...↓e the money to fight putting them in. Aquifer, waterways, and civilian hazards should be enough to stop this madness. The potential damage to the environment, ecological disaster, and civilian risks should be enough to stop putting these in our communities. Imagine an entire farming community, river Aquifer, salmon run, and farming economy ruined by just one of these fires. It's not worth the risk↓
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Dear Department of Ecology:
I strongly oppose any BESS PEIS framework that creates a presumption that utility-scale battery facilities are environmentally acceptable merely because they comply with industry standards such as NFPA 855.
Renewable Nor...↓thwest's comments emphasize industry standards, future design flexibility, siting near urban load centers and substations, and the separation of normal operations from failure events. BESS PEIS Scoping Comments RNW also acknowledges concerns involving fire, water and air impacts, noise, contamination during incidents, and BESS siting.
These issues require independent environmental analysis, not presumptions of safety.
Washington's SEPA rules provide that:
Environmental significance is site-specific. WAC 197-11-330 expressly recognizes that the same proposal may have a significant adverse impact in one location but not another.
Multiple impacts matter collectively. The same regulation recognizes that several marginal impacts considered together may result in a significant adverse impact.
Direct, indirect, and cumulative impacts must be considered within SEPA scoping.
An EIS must provide an impartial discussion of significant environmental impacts and reasonable alternatives, including mitigation measures.
Accordingly, I respectfully request that Ecology:
Reject any presumption that NFPA 855 compliance alone establishes environmental acceptability or appropriate siting.
Require meaningful site-specific analysis of fire and thermal-runaway consequences, air and water impacts, soil impacts, noise, wildfire conditions, emergency-response capability, and sensitive receptors.
Independently evaluate credible accident and contamination scenarios, rather than relying primarily on industry representations concerning fire behavior or contaminated runoff.
Do not presume that proximity to substations or urban load centers makes a site environmentally appropriate. SEPA expressly recognizes that environmental significance can depend on location.
Preserve environmental review of future battery technologies and materially different designs rather than assuming future systems are adequately addressed simply because they comply with an industry standard.
Evaluate direct, indirect, and cumulative impacts, including circumstances where multiple facilities or related infrastructure may affect the same community or environmental resources.
Do not allow claimed economic, reliability, or clean-energy benefits to replace impartial analysis of significant adverse environmental impacts, alternatives, and mitigation.
Washington's energy objectives are important, but they do not eliminate SEPA's environmental protections.
The BESS PEIS should establish a rigorous environmental baseline, not a statewide shortcut around meaningful project-specific environmental review. Public safety, environmental protection, and independent scientific analysis must remain central to every BESS siting decision.
Respectfully submitted,
Henrika Stich
Washington Resident↓
I strongly oppose any BESS PEIS framework that creates a presumption that utility-scale battery facilities are environmentally acceptable merely because they comply with industry standards such as NFPA 855.
Renewable Nor...↓thwest's comments emphasize industry standards, future design flexibility, siting near urban load centers and substations, and the separation of normal operations from failure events. BESS PEIS Scoping Comments RNW also acknowledges concerns involving fire, water and air impacts, noise, contamination during incidents, and BESS siting.
These issues require independent environmental analysis, not presumptions of safety.
Washington's SEPA rules provide that:
Environmental significance is site-specific. WAC 197-11-330 expressly recognizes that the same proposal may have a significant adverse impact in one location but not another.
Multiple impacts matter collectively. The same regulation recognizes that several marginal impacts considered together may result in a significant adverse impact.
Direct, indirect, and cumulative impacts must be considered within SEPA scoping.
An EIS must provide an impartial discussion of significant environmental impacts and reasonable alternatives, including mitigation measures.
Accordingly, I respectfully request that Ecology:
Reject any presumption that NFPA 855 compliance alone establishes environmental acceptability or appropriate siting.
Require meaningful site-specific analysis of fire and thermal-runaway consequences, air and water impacts, soil impacts, noise, wildfire conditions, emergency-response capability, and sensitive receptors.
Independently evaluate credible accident and contamination scenarios, rather than relying primarily on industry representations concerning fire behavior or contaminated runoff.
Do not presume that proximity to substations or urban load centers makes a site environmentally appropriate. SEPA expressly recognizes that environmental significance can depend on location.
Preserve environmental review of future battery technologies and materially different designs rather than assuming future systems are adequately addressed simply because they comply with an industry standard.
Evaluate direct, indirect, and cumulative impacts, including circumstances where multiple facilities or related infrastructure may affect the same community or environmental resources.
Do not allow claimed economic, reliability, or clean-energy benefits to replace impartial analysis of significant adverse environmental impacts, alternatives, and mitigation.
Washington's energy objectives are important, but they do not eliminate SEPA's environmental protections.
The BESS PEIS should establish a rigorous environmental baseline, not a statewide shortcut around meaningful project-specific environmental review. Public safety, environmental protection, and independent scientific analysis must remain central to every BESS siting decision.
Respectfully submitted,
Henrika Stich
Washington Resident↓
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Lithium-ion battery fires measured by the number of failure incidents per gigawatt hour deployed is not a true measurable for the air, water, nature, aquifer pollution from a fire. The number of Lithium-ion battery fires should be based on the number...↓ of Lithium-ion battery facility fires. Local fire districts and the public should not be responsible to fund and buy the specialty fire suppression equipment, higher electrical bills, the cost for environmental clean up, lack of water, tainted aquifer, etc. after a fire and or battery spill. How will the noise pollution for the constant hum of the facility. What steps are being mandated to clean up the critical aquifer so the local communities have safe untainted water. More data needs to be investigated, look into every fire, spill, interview people who live next to existing facilities to get the truth.↓
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Dear Washington State Department of Ecology,
I am a Snoqualmie-area resident, and I strongly oppose Jupiter Power's proposed Cascadia Ridge battery energy storage project near our community.
I am also very concerned about Jupiter Power's comments a...↓sking Ecology to make BESS permitting faster and more efficient while limiting how much weight is given to environmental impacts that they describe as site-specific.
Those site-specific impacts are exactly what matter to the people who will live near these facilities.
Large-scale battery storage facilities should not be placed near established neighborhoods, parks, wetlands, waterways, schools, or environmentally sensitive land without the strongest possible review and protections.
I urge Ecology to fully study the risks of battery fires and thermal runaway, toxic smoke and gases, contaminated firefighting runoff, groundwater and wetland impacts, emergency evacuation, setbacks from homes and parks, noise, wildlife impacts, steep slopes, seismic hazards, and the ability of local fire departments to safely respond to a major incident.
I also urge Ecology to establish clear statewide standards identifying locations where utility-scale BESS facilities should simply not be allowed.
Jupiter Power argues that many environmental impacts are too dependent on the individual project site to be useful in a statewide PEIS. I believe the opposite is true. Ecology should use this process to identify which site conditions create unacceptable risks and to establish strong protections before projects are permitted.
This PEIS should not become a tool for speeding up BESS development at the expense of the communities being asked to live beside these facilities.
I do not support the Cascadia Ridge project, and I do not believe a utility-scale BESS facility belongs next to the Snoqualmie community.
Please put public safety, environmental protection, and local communities first.
Thank you for considering my comments.
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I would decline the placement of this facility.
Are our local fire districts equipped to handle this if incident were to occur?
How should/ will the locals prepare in event of new emergencies?
Would the school bus barn be affected by damages as well,...↓ if so how will this be managed?
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Are our local fire districts equipped to handle this if incident were to occur?
How should/ will the locals prepare in event of new emergencies?
Would the school bus barn be affected by damages as well,...↓ if so how will this be managed?
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I think it would be a good idea for WA State to research BESS facilities located in other states and talk with individuals actually affected. There has been numerous articles about fires that can't be extinguished with water. They're just left to b...↓urn out while releasing noxious fumes into the air. Why put residents and wildlife at risk? Local fire departments need special training, equipment and clothing. Who pays for that? Ecology guidelines indicated they shouldn't be located, I think it was within 100 feet of a residential area, livestock or next to a critical aquifer. That seems too close considering problems occurring in other states. Washington State is known for its clean water and air. Why put that at risk for a facility that doesn't benefit the local community? It's only another resource for the utility companies to sell and make more money. Our state can do better. Please consider our environment rather than money.
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October 1, 2026
Clean Energy Coordination
Washington State Department of Ecology
PO Box 47709, Olympia, WA 98504-7709
Re: Scoping comments on the Battery Energy Storage System Facilities PEIS, and response to Jupiter Power's October 1, 2026 comment...↓s
Dear Ecology:
I am a Snoqualmie resident and I support a rigorous PEIS. I am writing because Jupiter Power's scoping comments ask Ecology to narrow the hazard analysis in ways that would make the PEIS less useful to the public and to permitting agencies. Ecology's scoping document notes that the facilities studied in the 2025 solar and wind PEISs were unlikely to be in or near cities, while stand-alone facilities could be sited in a variety of locations. The Cascadia Ridge proposal, across Snoqualmie Parkway from Snoqualmie Ridge and near Cascade View Elementary School, shows this is not hypothetical. I ask Ecology to scope the PEIS as follows.
1- Analyze each battery chemistry separately. Jupiter asserts that chemistry makes "little difference" for most impacts. For the impacts that matter most near homes (fire behavior, off-gassing, toxic releases, and water contamination), chemistry is the primary variable. Lithium-ion subtypes, sodium-ion, flow, and metal-air systems fail in different ways and require different mitigation. If Ecology expands beyond lithium-ion, each chemistry should receive its own hazard profile. Any chemistry not individually analyzed should be ineligible to tier to the PEIS.
2- Define facility tiers by stored energy and by distance to people. Jupiter asks that the analysis not be limited by capacity or duration. The consequences of a failure scale with stored energy, so tiers should be defined in MWh, not only MW. Ecology should also define proximity tiers by distance to homes, schools, childcare, and medical facilities. The PEIS should state plainly that projects outside the studied envelope require full project-level analysis.
3- Require independent expertise. I agree that fire safety analysis requires specialists. Those specialists should have no financial ties to BESS developers, manufacturers, or suppression vendors, and should disclose any conflicts. Ecology should also consult the State Fire Marshal, local fire districts, public health agencies, and independent academic researchers. The evidence base should include independent post-incident research, such as the peer-reviewed study that found elevated nickel, manganese, and cobalt in Elkhorn Slough soils after the January 2025 Moss Landing fire, which led to evacuation orders for about 1,200 residents.
4- Identify mitigation clearly. Jupiter urges caution in identifying potential impacts and recommending mitigation. That is contrary to the purpose of a PEIS and to SEPA. RCW 43.21C.031(2) requires an EIS to analyze probable significant adverse impacts and addresses alternatives including mitigation measures. The PEIS should set baseline mitigation, and the applicant should carry the burden of showing a measure is unnecessary at a given site. Mitigation should be measured against codes actually enforceable here. The scoping document acknowledges that the 2026 edition of NFPA 855 has not been adopted into state code and that state code references earlier UL editions. Where that gap exists, the PEIS should recommend mitigation beyond code minimums. This matters more for projects permitted through EFSEC, which may not be bound by local BESS ordinances.
5- Establish minimum setbacks based on generalizable harms. Jupiter argues that traditional impacts are too site-specific to analyze. Many are not: plume dispersion from thermal runaway, contaminated firefighting runoff, continuous noise from cooling systems and inverters, and local emergency response and evacuation capacity. Ecology's 2025 PEISs already identified noise within 1,000 feet of residents, hazardous air emissions from battery failure, and fire response as potential significant impacts. The PEIS should recommend minimum setbacks from homes, schools, drinking water wells, floodplains, and fish-bearing streams, scaled to the MWh tiers in item 2, and should model dispersion under adverse conditions including temperature inversions.
6- Analyze evacuation capacity as a siting factor. The PEIS should treat evacuation as a generalizable impact under public services and environmental health and safety. For any facility near a populated area, it should call for modeled evacuation time estimates based on the number and capacity of exit routes, the population inside a potential plume zone, dismissal and pickup logistics at multiple schools, and possible hospital evacuation. It should also analyze evacuation during a concurrent hazard such as flooding, landslides, or a highway closure. Snoqualmie Ridge illustrates the problem. The community has two ways in and out, and the proposed Cascadia Ridge site sits between them, off Snoqualmie Parkway. On December 10, 2025, a landslide closed eastbound I-90 near North Bend for nearly 24 hours. With traffic diverted onto local roads, traffic was snarled for hours. The PEIS should recommend against siting where the surrounding population cannot be evacuated within a defined time, and should have it's own independent studies to address when shelter-in-place is and is not protective. (Source: KIRO 7, https://www.kiro7.com/news/local/landslide-i-90-blocks-lanes-cars-near-north-bend/Q3VLQLQ6XVHBFPXJF3GTVXFSFU/)
7- Analyze earthquakes as an initiating event. Western Washington is exposed to both Cascadia subduction zone and shallow crustal fault earthquakes. Unlike a single-unit failure, an earthquake can damage many battery enclosures at once while also disabling grid power, cooling, monitoring, and suppression systems. The same event would damage roads, bridges, and water supply and would commit fire crews elsewhere. The PEIS should analyze this common-cause scenario, including aftershocks, rather than relying on failure rates drawn from normal operating conditions. It should identify seismic design and anchoring mitigation beyond code minimums, and recommend siting exclusions for fault zones, liquefaction-prone soils, and landslide hazard areas.
Thank you for considering these comments.
Sincerely,
Callie Brady
Snoqualmie, WA↓
Clean Energy Coordination
Washington State Department of Ecology
PO Box 47709, Olympia, WA 98504-7709
Re: Scoping comments on the Battery Energy Storage System Facilities PEIS, and response to Jupiter Power's October 1, 2026 comment...↓s
Dear Ecology:
I am a Snoqualmie resident and I support a rigorous PEIS. I am writing because Jupiter Power's scoping comments ask Ecology to narrow the hazard analysis in ways that would make the PEIS less useful to the public and to permitting agencies. Ecology's scoping document notes that the facilities studied in the 2025 solar and wind PEISs were unlikely to be in or near cities, while stand-alone facilities could be sited in a variety of locations. The Cascadia Ridge proposal, across Snoqualmie Parkway from Snoqualmie Ridge and near Cascade View Elementary School, shows this is not hypothetical. I ask Ecology to scope the PEIS as follows.
1- Analyze each battery chemistry separately. Jupiter asserts that chemistry makes "little difference" for most impacts. For the impacts that matter most near homes (fire behavior, off-gassing, toxic releases, and water contamination), chemistry is the primary variable. Lithium-ion subtypes, sodium-ion, flow, and metal-air systems fail in different ways and require different mitigation. If Ecology expands beyond lithium-ion, each chemistry should receive its own hazard profile. Any chemistry not individually analyzed should be ineligible to tier to the PEIS.
2- Define facility tiers by stored energy and by distance to people. Jupiter asks that the analysis not be limited by capacity or duration. The consequences of a failure scale with stored energy, so tiers should be defined in MWh, not only MW. Ecology should also define proximity tiers by distance to homes, schools, childcare, and medical facilities. The PEIS should state plainly that projects outside the studied envelope require full project-level analysis.
3- Require independent expertise. I agree that fire safety analysis requires specialists. Those specialists should have no financial ties to BESS developers, manufacturers, or suppression vendors, and should disclose any conflicts. Ecology should also consult the State Fire Marshal, local fire districts, public health agencies, and independent academic researchers. The evidence base should include independent post-incident research, such as the peer-reviewed study that found elevated nickel, manganese, and cobalt in Elkhorn Slough soils after the January 2025 Moss Landing fire, which led to evacuation orders for about 1,200 residents.
4- Identify mitigation clearly. Jupiter urges caution in identifying potential impacts and recommending mitigation. That is contrary to the purpose of a PEIS and to SEPA. RCW 43.21C.031(2) requires an EIS to analyze probable significant adverse impacts and addresses alternatives including mitigation measures. The PEIS should set baseline mitigation, and the applicant should carry the burden of showing a measure is unnecessary at a given site. Mitigation should be measured against codes actually enforceable here. The scoping document acknowledges that the 2026 edition of NFPA 855 has not been adopted into state code and that state code references earlier UL editions. Where that gap exists, the PEIS should recommend mitigation beyond code minimums. This matters more for projects permitted through EFSEC, which may not be bound by local BESS ordinances.
5- Establish minimum setbacks based on generalizable harms. Jupiter argues that traditional impacts are too site-specific to analyze. Many are not: plume dispersion from thermal runaway, contaminated firefighting runoff, continuous noise from cooling systems and inverters, and local emergency response and evacuation capacity. Ecology's 2025 PEISs already identified noise within 1,000 feet of residents, hazardous air emissions from battery failure, and fire response as potential significant impacts. The PEIS should recommend minimum setbacks from homes, schools, drinking water wells, floodplains, and fish-bearing streams, scaled to the MWh tiers in item 2, and should model dispersion under adverse conditions including temperature inversions.
6- Analyze evacuation capacity as a siting factor. The PEIS should treat evacuation as a generalizable impact under public services and environmental health and safety. For any facility near a populated area, it should call for modeled evacuation time estimates based on the number and capacity of exit routes, the population inside a potential plume zone, dismissal and pickup logistics at multiple schools, and possible hospital evacuation. It should also analyze evacuation during a concurrent hazard such as flooding, landslides, or a highway closure. Snoqualmie Ridge illustrates the problem. The community has two ways in and out, and the proposed Cascadia Ridge site sits between them, off Snoqualmie Parkway. On December 10, 2025, a landslide closed eastbound I-90 near North Bend for nearly 24 hours. With traffic diverted onto local roads, traffic was snarled for hours. The PEIS should recommend against siting where the surrounding population cannot be evacuated within a defined time, and should have it's own independent studies to address when shelter-in-place is and is not protective. (Source: KIRO 7, https://www.kiro7.com/news/local/landslide-i-90-blocks-lanes-cars-near-north-bend/Q3VLQLQ6XVHBFPXJF3GTVXFSFU/)
7- Analyze earthquakes as an initiating event. Western Washington is exposed to both Cascadia subduction zone and shallow crustal fault earthquakes. Unlike a single-unit failure, an earthquake can damage many battery enclosures at once while also disabling grid power, cooling, monitoring, and suppression systems. The same event would damage roads, bridges, and water supply and would commit fire crews elsewhere. The PEIS should analyze this common-cause scenario, including aftershocks, rather than relying on failure rates drawn from normal operating conditions. It should identify seismic design and anchoring mitigation beyond code minimums, and recommend siting exclusions for fault zones, liquefaction-prone soils, and landslide hazard areas.
Thank you for considering these comments.
Sincerely,
Callie Brady
Snoqualmie, WA↓
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Dear Department of Ecology:
I strongly object to recommendations provided by Clean Energy Coordination/CIP Terra Technologies that could allow compliance with the BESS PEIS to substitute for meaningful project-specific environmental review.
CIP ask...↓s Ecology to accommodate technologies that may not yet exist, allow certain equipment substitutions without new review, permit important technology information to remain unresolved during permitting, and establish a PEIS "consistency" process designed to reduce subsequent project-level analysis.
Ecology should reject any categorical approach of this kind.
Washington law requires agencies to properly define the proposal undergoing environmental review. Closely related proposals that effectively constitute a single course of action must be evaluated together where the criteria of WAC 197-11-060 are satisfied.
Equally important, WAC 197-11-600 expressly preserves additional or supplemental environmental review when substantial project changes or new information indicate probable significant adverse environmental impacts not covered by existing environmental documents. Ecology therefore should not declare in advance that future battery technologies, altered equipment, or post-permit substitutions will automatically be covered by today's PEIS.
CIP's own comments demonstrate why this protection is necessary. CIP identifies wildfire exposure, emergency-response capability, proximity to streams, wetlands and drinking-water sources, firefighting-water containment, battery chemistry, enclosure configuration, extreme-weather performance, and Tribal interests as relevant considerations. These factors cannot reasonably be presumed identical at every future location.
I therefore respectfully request that Ecology expressly provide that:
PEIS consistency does not constitute automatic project approval or eliminate independent SEPA review.
Future technology and material equipment changes remain subject to additional environmental review when required under SEPA.
Material safety and environmental information necessary to evaluate significant impacts cannot simply be deferred until after project approval.
A PEIS checklist or consistency worksheet cannot replace site-specific evaluation of fire, water, wildfire, emergency-response, noise, public-health, Tribal-resource, and other significant environmental impacts.
The PEIS must remain a baseline for environmental analysis, not a ceiling limiting what local agencies may examine when site conditions or new information demonstrate additional environmental risk.
Programmatic review can promote efficiency, but efficiency cannot come at the expense of meaningful environmental review or the safeguards Washington's SEPA regulations expressly preserve.
Respectfully submitted,
Henrika Stich
Washington Resident↓
I strongly object to recommendations provided by Clean Energy Coordination/CIP Terra Technologies that could allow compliance with the BESS PEIS to substitute for meaningful project-specific environmental review.
CIP ask...↓s Ecology to accommodate technologies that may not yet exist, allow certain equipment substitutions without new review, permit important technology information to remain unresolved during permitting, and establish a PEIS "consistency" process designed to reduce subsequent project-level analysis.
Ecology should reject any categorical approach of this kind.
Washington law requires agencies to properly define the proposal undergoing environmental review. Closely related proposals that effectively constitute a single course of action must be evaluated together where the criteria of WAC 197-11-060 are satisfied.
Equally important, WAC 197-11-600 expressly preserves additional or supplemental environmental review when substantial project changes or new information indicate probable significant adverse environmental impacts not covered by existing environmental documents. Ecology therefore should not declare in advance that future battery technologies, altered equipment, or post-permit substitutions will automatically be covered by today's PEIS.
CIP's own comments demonstrate why this protection is necessary. CIP identifies wildfire exposure, emergency-response capability, proximity to streams, wetlands and drinking-water sources, firefighting-water containment, battery chemistry, enclosure configuration, extreme-weather performance, and Tribal interests as relevant considerations. These factors cannot reasonably be presumed identical at every future location.
I therefore respectfully request that Ecology expressly provide that:
PEIS consistency does not constitute automatic project approval or eliminate independent SEPA review.
Future technology and material equipment changes remain subject to additional environmental review when required under SEPA.
Material safety and environmental information necessary to evaluate significant impacts cannot simply be deferred until after project approval.
A PEIS checklist or consistency worksheet cannot replace site-specific evaluation of fire, water, wildfire, emergency-response, noise, public-health, Tribal-resource, and other significant environmental impacts.
The PEIS must remain a baseline for environmental analysis, not a ceiling limiting what local agencies may examine when site conditions or new information demonstrate additional environmental risk.
Programmatic review can promote efficiency, but efficiency cannot come at the expense of meaningful environmental review or the safeguards Washington's SEPA regulations expressly preserve.
Respectfully submitted,
Henrika Stich
Washington Resident↓
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A battery thermal-runaway event must not be evaluated solely as a fire-code or emergency-response matter when the credible consequences of that event may affect SEPA environmental elements.
The PEIS should clearly distinguish fire-code compliance fr...↓om environmental review. Compliance with the International Fire Code, NFPA 855, UL 9540, UL 9540A, or approval by a local fire authority does not by itself evaluate probable impacts to air quality, soils, surface water, groundwater, critical aquifer recharge areas, wetlands, fish and wildlife, neighboring communities, transportation, evacuation routes, or public services.
Ecology should specifically address the risk that project-level lead agencies may characterize thermal-runaway consequences primarily as fire-safety matters and defer analysis of their environmental effects to later Hazard Mitigation Analyses, Emergency Response Plans, fire permits, building permits, or construction-stage review.
Where those consequences are reasonably foreseeable and relevant to determining whether a proposal may have significant adverse environmental impacts, the environmental analysis should occur early enough to inform the SEPA threshold determination and any discretionary land-use approval. Later fire-code or building-code review should supplement, not substitute for, the environmental review required under SEPA.
The PEIS should therefore provide clear guidance identifying which consequences of credible BESS failure scenarios must be addressed during SEPA review, even when separate fire, building, or emergency-response regulations also apply.
An environmental consequence does not cease to be a SEPA consequence merely because its initiating event is regulated by the fire code↓
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I would like to reiterate the environmental damage that results from BESS anywhere. Look no further than the 3 recent fires that burned at Moss Landing in Monterrey for weeks,the environmental damage and continued monitoring that provides the evidenc...↓e of widespread chemical arrays in the air and soil. Most recently, beginning of Sept. Summerville in Prince Rupert Islands Canada, burned all month and finally has been contained. Once burned, these facilities are more prone to repeated ignition. These fires can't be put out,pose a threat to firefighters and humans. Recently had to evacuate residents for days due to City Water or Sewage Utility battery fire in the area East Utah or Virginia? Is it worth the trade off of our pristine rural areas putting children and schools at risk for a Texas Company that could care less about the environmental damage done in the green state of Washington for a few kilowatts of power while lining the pockets of investors? This is greenwashing at best. It's time to reassess climate action requirements and incentives before our natural resources are destroyed! Ditto on the covert plan of Data Centers being built and the damage done to the residents, water use, energy required to run them and noise decibals all in the name of national security!↓
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I am writing to submit scoping comment on the Programmable Environment Impact Statement for stand alone utility scale lithium ion BESS facility's in Washington State.
I am Toni McWain and live in Tenino, WA. The Ecology study should define "suitabl...↓e areas". Rochester, Bucoda,Tenino, and other small towns on our large Pairire only rely on Aquafers for our everyday life, which includes humans, farm animals, pets, and wildlife. Our Aquafers, rivers, and creeks, are at risks for serious contaminations, if and when those BESS containers catch on fire, and they will. We have hotter heat than the bigger Counties up north of me. Have you done studies on flooding that happens on the Pairire? It happens every winter. We are a Pairire, FLAT LANDS. In the summer, we are also hotter than the bigger Counties north of me. That means our Pairire grasslands are brown and extremely dry! When a fire will start, that fire will spread so freaking fast! No time for firetruck to get there! Being that our towns are spread out, it will be too late. Do you have a fire truck in that facility to watch and control the fire? I've heard you can't put water on those lithium batteries. Let it burn! In Bucoda where you want to put in a BESS, it's near a creek, trees, and is home to a large Elk herd. What about the aquitic animals in the water, the animals living in the trees??? What about earthquakes? Since we just had one and living in Tenino, I felt it. Have you done a study on the glacier grounds that the Pairire is on top??? What about the constant noise emitting from those containers? It has to have severe health risks to humans, animals, pets, and wildlife. I bet the company personnel and the people installing these BESS containers will not be living anywhere near them! We know what happens to Tesla cars and cellphones of which uses lithium batteries. It seems the company's installing these containers really don't care about humans or animal or their waters or wildlife. The thing is, where these are being placed, this so called energy, being built by substations, will go to the bigger Counties north of me. It will not benefit anyone near them, but increase their electric bills. These need to not be placed in areas with any life around. Have you thought of eastern Washington in the desert? No trees, no water, no homes. Just sage brush and snakes.↓
I am Toni McWain and live in Tenino, WA. The Ecology study should define "suitabl...↓e areas". Rochester, Bucoda,Tenino, and other small towns on our large Pairire only rely on Aquafers for our everyday life, which includes humans, farm animals, pets, and wildlife. Our Aquafers, rivers, and creeks, are at risks for serious contaminations, if and when those BESS containers catch on fire, and they will. We have hotter heat than the bigger Counties up north of me. Have you done studies on flooding that happens on the Pairire? It happens every winter. We are a Pairire, FLAT LANDS. In the summer, we are also hotter than the bigger Counties north of me. That means our Pairire grasslands are brown and extremely dry! When a fire will start, that fire will spread so freaking fast! No time for firetruck to get there! Being that our towns are spread out, it will be too late. Do you have a fire truck in that facility to watch and control the fire? I've heard you can't put water on those lithium batteries. Let it burn! In Bucoda where you want to put in a BESS, it's near a creek, trees, and is home to a large Elk herd. What about the aquitic animals in the water, the animals living in the trees??? What about earthquakes? Since we just had one and living in Tenino, I felt it. Have you done a study on the glacier grounds that the Pairire is on top??? What about the constant noise emitting from those containers? It has to have severe health risks to humans, animals, pets, and wildlife. I bet the company personnel and the people installing these BESS containers will not be living anywhere near them! We know what happens to Tesla cars and cellphones of which uses lithium batteries. It seems the company's installing these containers really don't care about humans or animal or their waters or wildlife. The thing is, where these are being placed, this so called energy, being built by substations, will go to the bigger Counties north of me. It will not benefit anyone near them, but increase their electric bills. These need to not be placed in areas with any life around. Have you thought of eastern Washington in the desert? No trees, no water, no homes. Just sage brush and snakes.↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Gina Anderson and I live on Snoqualmie Ridge in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-...↓scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is SAFE for the people and rivers in the area, not just by where a facility could physically be built. Wildfire exposure and fire-district capacity should also be part of the map should inform what sites are suitable or unsuitable.
The study's map should clearly say where facilities should not go, not only where they could. Unsuitable sites should be clearly disqualified and designated as such on the study's map.
The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out. Proposed sites should not be close enough to homes or schools to affect them with noise and not close enough to waterways, homes, and schools that would be affected by a fire or fire response run-off.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for me and my family. We live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Gina Anderson
Snoqualmie Ridge
Snoqualmie, WA↓
My name is Gina Anderson and I live on Snoqualmie Ridge in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-...↓scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is SAFE for the people and rivers in the area, not just by where a facility could physically be built. Wildfire exposure and fire-district capacity should also be part of the map should inform what sites are suitable or unsuitable.
The study's map should clearly say where facilities should not go, not only where they could. Unsuitable sites should be clearly disqualified and designated as such on the study's map.
The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out. Proposed sites should not be close enough to homes or schools to affect them with noise and not close enough to waterways, homes, and schools that would be affected by a fire or fire response run-off.
I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for me and my family. We live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Gina Anderson
Snoqualmie Ridge
Snoqualmie, WA↓
No attachments
Thank you - Comment attached.
Attachments:
To the Department of Ecology, Clean Energy Coordination:
My name is Kyle Moylan and I live in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion bat...↓tery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Kyle Moylan
Snoqualmie, WA↓
My name is Kyle Moylan and I live in Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion bat...↓tery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Kyle Moylan
Snoqualmie, WA↓
No attachments
As a resident of Snoqualmie, I implore you to not approve the building and installation of the BESSProject. There are multiple examples of the dangers associated with these facilities. The risks of harm to the health of our community members, which i...↓ncludes children and families, is way to significant. Secondarily, and certainly of noteworthy concern, is the damage it would do to the desirability of our community, and thus the significant drop in property values. And then, of course, there are the environmental issues. A quick scan of the media shows many examples of communities needing to either evacuate or shelter in place due to the severely harmful effects when these things catch fire. And again, a media scanning will show that happens way too often. This should absolutely not be installed so close to homes, schools and the broader community. Let's find a place where it is not close to people and community members. I encourage you to ask yourself if you would allow to be installed close to your own home.↓
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Questions to WA ECY concerning catastrophic BESS failures outside Washington state, where getting defective BESS batteries to a recycler took two years for one, MOSS Landing's recent catastrophic failure last month reignited while trying to clean up ...↓the batteries damaged a 2015 fire. To compound that, the largest lithium battery recycler in the US exploded and has stopped all operation. The only BESS battery recycler in the western US (NV) lost federal funding and is looking to use used EV batteries in BESS facilities without processing the lithium from the used batteries.
Lithium Battery Fire: Missouri's Largest Recycling Plant Explodes! (now permanently closed)
https://youtu.be/WJ9v81N8xPA?si=OoWo-5Td2u8Uzpwl
Perth's Battery Recycling Fire: 80 Tons of Lithium-ion Batteries
https://youtu.be/SwkK8e97bUE?si=pEcG1YeYqqNABmYW
French Battery Recycling plant fire
https://youtube.com/shorts/ItqymyM3Pe4?si=wk-cdVyZZ6IRvqSm
Scotland Battery Recycling plant fire
https://youtube.com/shorts/dkRowJ1nukw?si=h1ZUb-qqD2ykDJKI
Excerpt from email
From: ECY RE Battery Stewardship Program
Sent: Monday, June 8, 2026 7:49 AM
To: peggyshepard@comcast.net
Hi Peggy,
While most of your other questions are beyond the scope and expertise of our agency, I passed them to staff in our Hazardous Waste and Toxic Reductions program, for review. See responses below.
Question: Do you know where large damaged industrial lithium-ion batteries can be transported to for recycling, and how long that recycler has been in business?
Answer: Several facilities across the United States accept and recycle damaged lithium-ion batteries. Potential options include:
• Redwood Materials in Carson City, NV - NVD980885685
• Li-Cycle in Rochester, NY - NYR000242891
• Cirba Solutions in Oakland County, Michigan - MIK241575671
• Ascend Elements in Covington, GA - GAR000094110 and GAR000096420
• Omega Harvested Metallurgy in Winchester, Ohio - OHD986983401
• Recycling Coordinators in Akron, OH - OHD986999480
Ecology cannot recommend one recycler over another, nor does Ecology know how long each has been in business.
Question: What is the procedure to handle large defective industrial lithium-ion batteries?
Answer: I recommend reading Ecology's Focus on: Lithium-Ion Batteries publication and Lithium-ion batteries webpage. Lithium batteries must be shipped as a hazardous material regulated by the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). USDOT has specific shipping requirements for damaged, defective, and recalled batteries. See Understanding the Risks of Damaged, Defective, or Recalled (DDR) Lithium Batteries | PHMSA for more information. Contact USDOT directly with questions.
All the best,
Brett
↓
Lithium Battery Fire: Missouri's Largest Recycling Plant Explodes! (now permanently closed)
https://youtu.be/WJ9v81N8xPA?si=OoWo-5Td2u8Uzpwl
Perth's Battery Recycling Fire: 80 Tons of Lithium-ion Batteries
https://youtu.be/SwkK8e97bUE?si=pEcG1YeYqqNABmYW
French Battery Recycling plant fire
https://youtube.com/shorts/ItqymyM3Pe4?si=wk-cdVyZZ6IRvqSm
Scotland Battery Recycling plant fire
https://youtube.com/shorts/dkRowJ1nukw?si=h1ZUb-qqD2ykDJKI
Excerpt from email
From: ECY RE Battery Stewardship Program
Sent: Monday, June 8, 2026 7:49 AM
To: peggyshepard@comcast.net
Hi Peggy,
While most of your other questions are beyond the scope and expertise of our agency, I passed them to staff in our Hazardous Waste and Toxic Reductions program, for review. See responses below.
Question: Do you know where large damaged industrial lithium-ion batteries can be transported to for recycling, and how long that recycler has been in business?
Answer: Several facilities across the United States accept and recycle damaged lithium-ion batteries. Potential options include:
• Redwood Materials in Carson City, NV - NVD980885685
• Li-Cycle in Rochester, NY - NYR000242891
• Cirba Solutions in Oakland County, Michigan - MIK241575671
• Ascend Elements in Covington, GA - GAR000094110 and GAR000096420
• Omega Harvested Metallurgy in Winchester, Ohio - OHD986983401
• Recycling Coordinators in Akron, OH - OHD986999480
Ecology cannot recommend one recycler over another, nor does Ecology know how long each has been in business.
Question: What is the procedure to handle large defective industrial lithium-ion batteries?
Answer: I recommend reading Ecology's Focus on: Lithium-Ion Batteries publication and Lithium-ion batteries webpage. Lithium batteries must be shipped as a hazardous material regulated by the U.S. Department of Transportation (DOT) Pipeline and Hazardous Materials Safety Administration (PHMSA). USDOT has specific shipping requirements for damaged, defective, and recalled batteries. See Understanding the Risks of Damaged, Defective, or Recalled (DDR) Lithium Batteries | PHMSA for more information. Contact USDOT directly with questions.
All the best,
Brett
No attachments
Attachments:
The following is an excerpt from a longer email from Bret (BatteryStewarship@ECY.WA.GOV) and peggyshepard@comcast.net
From: ECY RE Battery Stewardship Program
Sent: Monday, June 8, 2026 7:49 AM
To: peggyshepard@comcast.net
Hi Peggy,
L...↓arge batteries ... used in a battery energy storage system are not covered under Ecology's battery stewardship law.
Bret
_________________________________________________________________________
Washington State has laws for battery stewardship (Chapter 70A.555 RCW BATTERIES—ENVIRONMENTAL STEWARDSHIP), however it does not cover BESS batteries.
https://ecology.wa.gov/about-us/who-we-are/our-programs/hazardous-waste-toxics-reduction
______________________________________________________________________________________
Bret suggested I make a public records request from WA State Hazardous Waste and Toxics Reduction for any email describing the department members concerns because there are increasing numbers of lithium EV fires, they want a better understanding to properly assess the environmental impacts. 360-407-6700
I have not made a public records request yet.↓
From: ECY RE Battery Stewardship Program
Sent: Monday, June 8, 2026 7:49 AM
To: peggyshepard@comcast.net
Hi Peggy,
L...↓arge batteries ... used in a battery energy storage system are not covered under Ecology's battery stewardship law.
Bret
_________________________________________________________________________
Washington State has laws for battery stewardship (Chapter 70A.555 RCW BATTERIES—ENVIRONMENTAL STEWARDSHIP), however it does not cover BESS batteries.
https://ecology.wa.gov/about-us/who-we-are/our-programs/hazardous-waste-toxics-reduction
______________________________________________________________________________________
Bret suggested I make a public records request from WA State Hazardous Waste and Toxics Reduction for any email describing the department members concerns because there are increasing numbers of lithium EV fires, they want a better understanding to properly assess the environmental impacts. 360-407-6700
I have not made a public records request yet.↓
No attachments
Dear Washington State Department of Ecology,
I am a Snoqualmie-area resident writing to express my strong opposition to the siting of large-scale Battery Energy Storage System facilities near established residential communities, including Jupiter Po...↓wer's proposed Cascadia Ridge Resiliency Energy Storage project near Snoqualmie Ridge.
I urge Ecology to use this PEIS process to establish strong statewide protections that put the safety of residents, emergency responders, drinking water, wildlife, and environmentally sensitive lands ahead of accelerated development of utility-scale BESS projects.
I am particularly concerned by Jupiter Power's comments asking Ecology to streamline BESS permitting while limiting the extent to which traditional environmental impacts are addressed at the programmatic level. Jupiter argues that many issues involving water quality, wetlands, wildlife habitat and mitigation are too site-specific to be particularly useful in the PEIS.
I strongly disagree with that approach.
The fact that risks vary depending on location is exactly why Ecology should study them comprehensively now. The PEIS should identify locations where large-scale BESS facilities may simply be inappropriate because of proximity to homes, parks, schools, environmentally sensitive areas, wetlands, waterways, steep slopes, flood-prone areas, limited evacuation routes, or communities that do not have the emergency-response resources necessary for a major battery incident.
For communities such as Snoqualmie, these are not abstract concerns.
Jupiter Power is proposing a large utility-scale battery storage facility south of Fisher Creek Park near Snoqualmie Ridge. This project would place major energy infrastructure close to an established community and recreational and environmentally sensitive areas. Jupiter has also chosen to pursue approval through the Washington State Energy Facility Site Evaluation Council rather than continue through the local King County permitting process.
That makes strong statewide standards even more important.
At minimum, I ask Ecology to fully examine:
• Fire and thermal-runaway risks, including cascading failures and reignition.
• Toxic gases, smoke and particulate emissions from battery fires and their potential effects on nearby residents and emergency responders.
• Contaminated firefighting water, runoff, soil contamination, groundwater impacts and impacts to nearby streams and wetlands.
• Minimum setbacks from homes, schools, parks, trails and environmentally sensitive areas.
• Emergency evacuation requirements, including whether surrounding road networks can safely accommodate an evacuation during a major incident.
• Local fire-department capability, specialized equipment requirements, water requirements, training and costs placed on local taxpayers.
• Flooding, seismic hazards, steep slopes, landslide risks and other site-specific geological conditions.
• Noise and lighting impacts during both normal operation and emergency conditions.
• Wildlife, habitat and wetland impacts.
• Cumulative impacts when energy infrastructure is concentrated near existing communities.
• Full end-of-life requirements, including battery replacement, decommissioning, disposal, recycling and financial responsibility if a developer or operator ceases operations.
• Independent monitoring and emergency-response requirements rather than relying primarily on information supplied by project developers.
I also ask Ecology not to assume that the economic or grid benefits claimed by BESS developers outweigh the environmental or public-safety risks of a particular site. Those questions should be evaluated independently and transparently.
Jupiter Power states that battery projects may continue to grow in capacity and duration and asks Ecology not to limit the PEIS analysis based on facility size or storage duration. If increasingly large projects are contemplated, then increasingly strong siting, setback, environmental and emergency-response protections should be examined as well.
Washington should not create a permitting framework that makes it easier to place increasingly large battery facilities near residential communities without first establishing clear safety standards and identifying locations where this type of development should not occur.
For Snoqualmie, I oppose the Cascadia Ridge project and do not believe a utility-scale BESS facility of this nature belongs next to our community.
I respectfully ask Ecology to ensure that this PEIS does not become a tool primarily for accelerating BESS permitting. It should instead provide state and local decision-makers with strong, independent standards for determining when a site presents unacceptable risks and when a project should not proceed.
Please fully consider the concerns of communities that will be asked to live next to these facilities.
Thank you for considering my comments.↓
I am a Snoqualmie-area resident writing to express my strong opposition to the siting of large-scale Battery Energy Storage System facilities near established residential communities, including Jupiter Po...↓wer's proposed Cascadia Ridge Resiliency Energy Storage project near Snoqualmie Ridge.
I urge Ecology to use this PEIS process to establish strong statewide protections that put the safety of residents, emergency responders, drinking water, wildlife, and environmentally sensitive lands ahead of accelerated development of utility-scale BESS projects.
I am particularly concerned by Jupiter Power's comments asking Ecology to streamline BESS permitting while limiting the extent to which traditional environmental impacts are addressed at the programmatic level. Jupiter argues that many issues involving water quality, wetlands, wildlife habitat and mitigation are too site-specific to be particularly useful in the PEIS.
I strongly disagree with that approach.
The fact that risks vary depending on location is exactly why Ecology should study them comprehensively now. The PEIS should identify locations where large-scale BESS facilities may simply be inappropriate because of proximity to homes, parks, schools, environmentally sensitive areas, wetlands, waterways, steep slopes, flood-prone areas, limited evacuation routes, or communities that do not have the emergency-response resources necessary for a major battery incident.
For communities such as Snoqualmie, these are not abstract concerns.
Jupiter Power is proposing a large utility-scale battery storage facility south of Fisher Creek Park near Snoqualmie Ridge. This project would place major energy infrastructure close to an established community and recreational and environmentally sensitive areas. Jupiter has also chosen to pursue approval through the Washington State Energy Facility Site Evaluation Council rather than continue through the local King County permitting process.
That makes strong statewide standards even more important.
At minimum, I ask Ecology to fully examine:
• Fire and thermal-runaway risks, including cascading failures and reignition.
• Toxic gases, smoke and particulate emissions from battery fires and their potential effects on nearby residents and emergency responders.
• Contaminated firefighting water, runoff, soil contamination, groundwater impacts and impacts to nearby streams and wetlands.
• Minimum setbacks from homes, schools, parks, trails and environmentally sensitive areas.
• Emergency evacuation requirements, including whether surrounding road networks can safely accommodate an evacuation during a major incident.
• Local fire-department capability, specialized equipment requirements, water requirements, training and costs placed on local taxpayers.
• Flooding, seismic hazards, steep slopes, landslide risks and other site-specific geological conditions.
• Noise and lighting impacts during both normal operation and emergency conditions.
• Wildlife, habitat and wetland impacts.
• Cumulative impacts when energy infrastructure is concentrated near existing communities.
• Full end-of-life requirements, including battery replacement, decommissioning, disposal, recycling and financial responsibility if a developer or operator ceases operations.
• Independent monitoring and emergency-response requirements rather than relying primarily on information supplied by project developers.
I also ask Ecology not to assume that the economic or grid benefits claimed by BESS developers outweigh the environmental or public-safety risks of a particular site. Those questions should be evaluated independently and transparently.
Jupiter Power states that battery projects may continue to grow in capacity and duration and asks Ecology not to limit the PEIS analysis based on facility size or storage duration. If increasingly large projects are contemplated, then increasingly strong siting, setback, environmental and emergency-response protections should be examined as well.
Washington should not create a permitting framework that makes it easier to place increasingly large battery facilities near residential communities without first establishing clear safety standards and identifying locations where this type of development should not occur.
For Snoqualmie, I oppose the Cascadia Ridge project and do not believe a utility-scale BESS facility of this nature belongs next to our community.
I respectfully ask Ecology to ensure that this PEIS does not become a tool primarily for accelerating BESS permitting. It should instead provide state and local decision-makers with strong, independent standards for determining when a site presents unacceptable risks and when a project should not proceed.
Please fully consider the concerns of communities that will be asked to live next to these facilities.
Thank you for considering my comments.↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Jesse Correia and I live at 6535 Fairway Ave Se. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, the Cascades Ridge by Jupiter Power project, in the same air basin, fire district, and hospital service area. My children attend school near a proposed stand-alone BESS site, at Cascade Ciew. My household depends on Snoqualmie Parkeay/HWY 18, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jesse Correia
6535 Fairway Ave Se↓
My name is Jesse Correia and I live at 6535 Fairway Ave Se. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q1 · Facility types — Which kinds of battery facilities get studied.
I would like the study to look at stand-alone sites near homes and neighborhoods, not the remote ones it studied before, since Ecology admits these sites are smaller and "could be sited in a variety of locations." The study should assume facilities would be built to the rules Washington has actually adopted, and say what the newest standards would change, since Ecology admits the state's fire code is behind them. I ask that the PEIS evaluate the full range of stand-alone facilities actually being proposed in Washington — including large container-based lithium-ion installations sited near homes, schools, and constrained road networks — and that it analyze those facilities as built to the code Washington has actually adopted, drawing on independent safety data rather than industry assurances, and identify the most recent safety standards as required mitigation.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, the Cascades Ridge by Jupiter Power project, in the same air basin, fire district, and hospital service area. My children attend school near a proposed stand-alone BESS site, at Cascade Ciew. My household depends on Snoqualmie Parkeay/HWY 18, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jesse Correia
6535 Fairway Ave Se↓
No attachments
Please do not approve any BESS facilities in or near Tenino or Washington State. Fires involving battery energy storage systems cannot be safely extinguished with water and can cause significant, lasting damage to the environment, wildlife, air quali...↓ty, soil, and groundwater.
This proposal appears to be driven primarily by the Climate Commitment Act. However, allowing BESS facilities that pose these risks could undermine the environmental goals the act was intended to support.↓
This proposal appears to be driven primarily by the Climate Commitment Act. However, allowing BESS facilities that pose these risks could undermine the environmental goals the act was intended to support.↓
No attachments
FIREFIGHTERS LOCAL 1014 AFF AFL CIO
LOS ANGELES COUNTY
FIRE FIGHTERS LOCAL 1014
3460 FLETCHER AVE. EL MONTE, CA 91731 . (310) 639-1014 . FAX (310) 639-5314
IAFF
International Association Fire Fighters
AFL-CIO
CLC
January 2, 2026
Anthony Marrone, ...↓Fire Chief
Los Angeles County Fire Fighters Local 1014
1320 N. Eastern Avenue
Los Angeles, CA 90063
CEASE AND DESIST NOTICE: Consideration or Approval of Energy Storage System (ESS) Facilities Adjacent to Fire
Station 43 or Residential Occupancies
Dear Chief Marrone:
This correspondence serves as a formal CEASE AND DESIST NOTICE on behalf of the Los Angeles County Firefighters, IAFF
Local 1014.
IAFF Local 1014 hereby demands that the Los Angeles County Fire District, Fire Prevention Bureau, Fire Marshal's Office, and
any subordinate authority immediately cease and desist from any consideration, review, approval, conditional approval, or
facilitation of an Energy Storage System (ESS) facility proposed to be located adjacent to Los Angeles County Fire Station 43, or in
proximity to residential occupancies within Los Angeles County.
NOTICE OF UNACCEPTABLE AND FORESEEABLE DANGER
The siting of an ESS facility next to an occupied fire station-where firefighters work and reside twenty-four (24) hours per day-
constitutes an unacceptable, unsafe, and indefensible action that directly contradicts established fire protection engineering
principles, firefighter safety standards, and the intent of applicable codes. ESS facilities are recognized as high-hazard industrial
installations that present uniquely severe risks, including but not limited to:
. Thermal runaway and cascading battery failure
. Deflagration and explosive overpressure events
. Release of highly toxic gases, including hydrogen fluoride (HF)
. Delayed ignition and re-ignition without warning
Fire stations are mixed-use facilities containing residential occupancies under the California Building Code, California Fire Code,
and Los Angeles County amendments. Firefighters live, eat, and sleep within these facilities. Placing an ESS facility adjacent to
such an occupancy would never be permitted for traditional residential housing and is equally impermissible here.
KNOWN AND DOCUMENTED FIRE SERVICE INJURY HISTORY
Lithium-ion battery incidents, using the same technology deployed in ESS facilities, have already caused serious firefighter injuries
and long-term health consequences.
In April 2025, four Sacramento Fire Department firefighters were hospitalized following exposure to toxic off-gassing during a Tesla
electric vehicle battery thermal runaway event. No explosion occurred, yet all four suffered significant inhalation injuries from
hydrogen fluoride and related byproducts, with reports indicating potential permanent disability and inability to return to duty.
This incident directly prompted the advancement of SB 283 (Laird) and AB 841 (Patel), which formally recognizes the serious
occupational hazards posed by lithium-ion battery fires and the need for enhanced firefighter protections against toxic exposure,
cancer risk, respiratory disease, and neurological harm.
Large-scale ESS incidents-including the Moss Landing BESS fire (2025), Gateway Energy Storage fire (San Diego County), and
the McMicken ESS explosion-further confirm that these facilities can catastrophically fail without warning and require strictly
defensive firefighting tactics, exclusion zones, and evacuation to prevent injury or loss of life.
These realities alone establish that ESS facilities do not belong near occupied fire stations or residential communities.
RESIDENTIAL COMMUNITY SAFETY
IAFF Local 1014's opposition is not limited to fire stations. ESS facilities pose an existential threat to public health and safety
when located near residential homes, schools, or neighborhoods. Civilians-including children, seniors, and medically vulnerable
populations-have no ability to mitigate or respond to ESS failures involving toxic gas release, explosion, or long-duration fire
events.
Local 1014 does not oppose energy storage technology in principle. However, such facilities must be sited only in remote, non-
residential areas of Los Angeles County, where failure does not endanger the public or emergency responders.
DEMAND TO CEASE AND DESIST
Accordingly, IAFF Local 1014 hereby demands that you:
1. Immediately cease and desist from any further consideration, review, or approval of an ESS facility adjacent to Fire
Station 43
2. Cease and desist from approving ESS facilities in proximity to residential occupancies within Los Angeles County.
3. Confirm that no permits, conditional approvals, variances, or discretionary actions will be granted for such siting.
NOTICE OF ESCALATION AND LIABILITY
Should Local 1014 become aware that Fire Prevention personnel or the Fire Marshal's Office has approved or intends to approve
ESS facilities near fire stations or residential communities, this matter will be immediately escalated to the Los Angeles County
Board of Supervisors. California Professional Firefighters (CPF), the state union representing over 30,000 firefighters, is fully
aware of this issue and stands in full support of Local 1014.
Any future injury, long-term health impact, or loss of life resulting from an ESS incident approved despite this notice will rest
solely with:
. The Los Angeles County Fire District
. The Fire Marshal and Fire Prevention Division
. The County of Los Angeles and all approving authorities
The dangers are known, foreseeable, and preventable.
You are hereby directed to provide a formal written response within five (5) business days confirming that this proposal has been
rejected and removed from further departmental or County consideration. Failure to do so will be interpreted as a refusal to comply
with this notice and will result in immediate escalation.
Vice President Tony Carcioppolo will be handling this issue for Local 1014, please contact him with any questions you may have
and with your response.
Respectfully,
DAVID GILLOTTE
President
Los Angeles County Firefighters
IAFF Local 1014
DAVE GILLOTTE, President KURT KOBLER, 1st Vice President TONY CARCIOPPOLO, 2nd Vice President MATTHEW DUHAMELL, Treasurer
EXECUTIVE BOARD MEMBERS: CHRIS CULLEN JASON GREEN AARON KATON CHRIS READE CHRISTIAN REYNOSO DEREK URWIN
REPRESENTING PROFESSIONAL FIREFIGHTERS IN 60 CITIES AND THE COUNTY OF LOS ANGELES
Affiliated with ... International Association of Fire Fighters, AFL-CIO . California Professional Firefighters, AFL-CIO
California Labor Federation, AFL-CIO . L.A. County Federation of Labor, AFL-CIO↓
LOS ANGELES COUNTY
FIRE FIGHTERS LOCAL 1014
3460 FLETCHER AVE. EL MONTE, CA 91731 . (310) 639-1014 . FAX (310) 639-5314
IAFF
International Association Fire Fighters
AFL-CIO
CLC
January 2, 2026
Anthony Marrone, ...↓Fire Chief
Los Angeles County Fire Fighters Local 1014
1320 N. Eastern Avenue
Los Angeles, CA 90063
CEASE AND DESIST NOTICE: Consideration or Approval of Energy Storage System (ESS) Facilities Adjacent to Fire
Station 43 or Residential Occupancies
Dear Chief Marrone:
This correspondence serves as a formal CEASE AND DESIST NOTICE on behalf of the Los Angeles County Firefighters, IAFF
Local 1014.
IAFF Local 1014 hereby demands that the Los Angeles County Fire District, Fire Prevention Bureau, Fire Marshal's Office, and
any subordinate authority immediately cease and desist from any consideration, review, approval, conditional approval, or
facilitation of an Energy Storage System (ESS) facility proposed to be located adjacent to Los Angeles County Fire Station 43, or in
proximity to residential occupancies within Los Angeles County.
NOTICE OF UNACCEPTABLE AND FORESEEABLE DANGER
The siting of an ESS facility next to an occupied fire station-where firefighters work and reside twenty-four (24) hours per day-
constitutes an unacceptable, unsafe, and indefensible action that directly contradicts established fire protection engineering
principles, firefighter safety standards, and the intent of applicable codes. ESS facilities are recognized as high-hazard industrial
installations that present uniquely severe risks, including but not limited to:
. Thermal runaway and cascading battery failure
. Deflagration and explosive overpressure events
. Release of highly toxic gases, including hydrogen fluoride (HF)
. Delayed ignition and re-ignition without warning
Fire stations are mixed-use facilities containing residential occupancies under the California Building Code, California Fire Code,
and Los Angeles County amendments. Firefighters live, eat, and sleep within these facilities. Placing an ESS facility adjacent to
such an occupancy would never be permitted for traditional residential housing and is equally impermissible here.
KNOWN AND DOCUMENTED FIRE SERVICE INJURY HISTORY
Lithium-ion battery incidents, using the same technology deployed in ESS facilities, have already caused serious firefighter injuries
and long-term health consequences.
In April 2025, four Sacramento Fire Department firefighters were hospitalized following exposure to toxic off-gassing during a Tesla
electric vehicle battery thermal runaway event. No explosion occurred, yet all four suffered significant inhalation injuries from
hydrogen fluoride and related byproducts, with reports indicating potential permanent disability and inability to return to duty.
This incident directly prompted the advancement of SB 283 (Laird) and AB 841 (Patel), which formally recognizes the serious
occupational hazards posed by lithium-ion battery fires and the need for enhanced firefighter protections against toxic exposure,
cancer risk, respiratory disease, and neurological harm.
Large-scale ESS incidents-including the Moss Landing BESS fire (2025), Gateway Energy Storage fire (San Diego County), and
the McMicken ESS explosion-further confirm that these facilities can catastrophically fail without warning and require strictly
defensive firefighting tactics, exclusion zones, and evacuation to prevent injury or loss of life.
These realities alone establish that ESS facilities do not belong near occupied fire stations or residential communities.
RESIDENTIAL COMMUNITY SAFETY
IAFF Local 1014's opposition is not limited to fire stations. ESS facilities pose an existential threat to public health and safety
when located near residential homes, schools, or neighborhoods. Civilians-including children, seniors, and medically vulnerable
populations-have no ability to mitigate or respond to ESS failures involving toxic gas release, explosion, or long-duration fire
events.
Local 1014 does not oppose energy storage technology in principle. However, such facilities must be sited only in remote, non-
residential areas of Los Angeles County, where failure does not endanger the public or emergency responders.
DEMAND TO CEASE AND DESIST
Accordingly, IAFF Local 1014 hereby demands that you:
1. Immediately cease and desist from any further consideration, review, or approval of an ESS facility adjacent to Fire
Station 43
2. Cease and desist from approving ESS facilities in proximity to residential occupancies within Los Angeles County.
3. Confirm that no permits, conditional approvals, variances, or discretionary actions will be granted for such siting.
NOTICE OF ESCALATION AND LIABILITY
Should Local 1014 become aware that Fire Prevention personnel or the Fire Marshal's Office has approved or intends to approve
ESS facilities near fire stations or residential communities, this matter will be immediately escalated to the Los Angeles County
Board of Supervisors. California Professional Firefighters (CPF), the state union representing over 30,000 firefighters, is fully
aware of this issue and stands in full support of Local 1014.
Any future injury, long-term health impact, or loss of life resulting from an ESS incident approved despite this notice will rest
solely with:
. The Los Angeles County Fire District
. The Fire Marshal and Fire Prevention Division
. The County of Los Angeles and all approving authorities
The dangers are known, foreseeable, and preventable.
You are hereby directed to provide a formal written response within five (5) business days confirming that this proposal has been
rejected and removed from further departmental or County consideration. Failure to do so will be interpreted as a refusal to comply
with this notice and will result in immediate escalation.
Vice President Tony Carcioppolo will be handling this issue for Local 1014, please contact him with any questions you may have
and with your response.
Respectfully,
DAVID GILLOTTE
President
Los Angeles County Firefighters
IAFF Local 1014
DAVE GILLOTTE, President KURT KOBLER, 1st Vice President TONY CARCIOPPOLO, 2nd Vice President MATTHEW DUHAMELL, Treasurer
EXECUTIVE BOARD MEMBERS: CHRIS CULLEN JASON GREEN AARON KATON CHRIS READE CHRISTIAN REYNOSO DEREK URWIN
REPRESENTING PROFESSIONAL FIREFIGHTERS IN 60 CITIES AND THE COUNTY OF LOS ANGELES
Affiliated with ... International Association of Fire Fighters, AFL-CIO . California Professional Firefighters, AFL-CIO
California Labor Federation, AFL-CIO . L.A. County Federation of Labor, AFL-CIO↓
To the Department of Ecology, Clean Energy Coordination:
My name is Judy PankratzWhite and I live at 4631 357th Ave SE, Fall City, WA 98024. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone,...↓ utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed for Snoqualmie, near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Wildfire exposure and fire-district capacity should be part of the map, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities." Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby and the potential for long term damages. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. It should consider what equipment might be necessary for safe evacuation for residents and the availablilty of equipment, transportation and routes during all seasons and weather conditions. I suffer from asthma and congestive heart failure. I am extremely susceptible to polluted and contaminated air. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. Noise travels well in rural areas, especially downhill and over water. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. Smoke, chemicals and contamination tend to flow down in elevation...My home is on the valley floor, about 1000 feet in elevation below a proposed site. It is in a restricted area because of water recharge to wells and the Snoqualmie River. It's crucial that responder availability, training, hard-to-extinguish fires, toxic air, harm to air, water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Our first responders are volunteer firemen, and a single county sheriff officer for an area that takes hours to cross. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream and downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area. My household drinking water comes from a private well. My household depends on SR 202, which is our only route to and from home, and is often closed during flood events. SR 202 is a limited, 2-lane emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
I understand these batteries are needed for modern living, but the quality of living and the resources to deal with emergencies MUST be thoroughly investigated BEFORE siting and construction.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
JUDY C. PANKRATZ-WHITE
4631 357th Ave SE, Fall City, WA 98024↓
My name is Judy PankratzWhite and I live at 4631 357th Ave SE, Fall City, WA 98024. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone,...↓ utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed for Snoqualmie, near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's geographic assumptions should screen out places with private wells, floodplains, earthquake faults, and neighborhoods with one road out, because site details will be left to later reviews. Wildfire exposure and fire-district capacity should be part of the map, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities." Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby and the potential for long term damages. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. It should consider what equipment might be necessary for safe evacuation for residents and the availablilty of equipment, transportation and routes during all seasons and weather conditions. I suffer from asthma and congestive heart failure. I am extremely susceptible to polluted and contaminated air. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. Noise travels well in rural areas, especially downhill and over water. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. Smoke, chemicals and contamination tend to flow down in elevation...My home is on the valley floor, about 1000 feet in elevation below a proposed site. It is in a restricted area because of water recharge to wells and the Snoqualmie River. It's crucial that responder availability, training, hard-to-extinguish fires, toxic air, harm to air, water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Our first responders are volunteer firemen, and a single county sheriff officer for an area that takes hours to cross. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream and downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area. My household drinking water comes from a private well. My household depends on SR 202, which is our only route to and from home, and is often closed during flood events. SR 202 is a limited, 2-lane emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
I understand these batteries are needed for modern living, but the quality of living and the resources to deal with emergencies MUST be thoroughly investigated BEFORE siting and construction.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
JUDY C. PANKRATZ-WHITE
4631 357th Ave SE, Fall City, WA 98024↓
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As a Snoqualmie resident, I ask Ecology to prioritize community safety in the BESS PEIS and address the following:
Section 4, pages 16–19: Evaluate credible major incidents, including thermal runaway, explosions, prolonged fires, and reignition. Asse...↓ss potential hazardous emissions affecting residents, schools, and responders, including how terrain and weather influence exposure.
Section 5.3, pages 20–21: Evaluate siting near homes, schools, forests, and waterways. Include seismic, flood, landslide, and wildfire risks, emergency access, evacuation routes, and evidence-based separation distances.
Section 5.4, pages 21–22: Study contaminated firefighting runoff, impacts to water and wildlife, and local emergency response capacity. Evaluate public notification, evacuation and shelter-in-place needs, monitoring, cleanup, and financial assurances. Assess whether safeguards remain effective during equipment failures or simultaneous emergencies.
Section 3.1.2.1, page 16, and Section 5.2, page 20: Examine gaps between adopted and newer safety standards, limitations of testing, and safety differences among battery technologies, including sodium-ion alternatives.
Sections 1.3–1.4, pages 11–12: Clearly identify uncertainties, impacts that cannot reliably be mitigated, and safety questions requiring project-specific review.
The public deserves clear findings that support safe siting and meaningful participation before individual projects proceed.↓
Section 4, pages 16–19: Evaluate credible major incidents, including thermal runaway, explosions, prolonged fires, and reignition. Asse...↓ss potential hazardous emissions affecting residents, schools, and responders, including how terrain and weather influence exposure.
Section 5.3, pages 20–21: Evaluate siting near homes, schools, forests, and waterways. Include seismic, flood, landslide, and wildfire risks, emergency access, evacuation routes, and evidence-based separation distances.
Section 5.4, pages 21–22: Study contaminated firefighting runoff, impacts to water and wildlife, and local emergency response capacity. Evaluate public notification, evacuation and shelter-in-place needs, monitoring, cleanup, and financial assurances. Assess whether safeguards remain effective during equipment failures or simultaneous emergencies.
Section 3.1.2.1, page 16, and Section 5.2, page 20: Examine gaps between adopted and newer safety standards, limitations of testing, and safety differences among battery technologies, including sodium-ion alternatives.
Sections 1.3–1.4, pages 11–12: Clearly identify uncertainties, impacts that cannot reliably be mitigated, and safety questions requiring project-specific review.
The public deserves clear findings that support safe siting and meaningful participation before individual projects proceed.↓
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Please do not allow BESS's to be sited near homes, schools, hospitals, water sources, care/retirement facilities, wetlands, wildlife areas, etc. The environmental impact as well as noise impacts and dangers to surrounding people and areas is far too ...↓great to allow them to be put in areas like this. Thank you.↓
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Environmental Impact of Lithium-Ion Battery Incidents compared to other Common Incidents.
Attachments:
Attachments:
It's difficult to assess how much damage to our health BESS fires have caused. Keep in mind that large lithium batteries are significantly more dangerous than smaller ones, and the smaller ones kill.
Lithium-Ion Hospitalizes Firefighters
https://yo...↓utu.be/lADLvwAJs-c?si=7r-lrbNNf3K6VDU7
Comments
@mojoneko8303
1 month ago
I was a firefighter for 28 years. I hired on in the mid 70's when SCBA's were first becoming a thing. A lot of the older guys wouldn't use them because the early SCBA's were very heavy and cumbersome. They would give me a hard time for using them. This was near the end of the "Leather Lung" era of Fire Fighting. These guys would come out of a structure fire after extinguishing it looking like they had just got off a shift in a coal mine sit down on the tailboard and light up a cigarette. When I hired on I was told that Fire Fighters typically died within 5 years of retirement. I was determined to beat those odds and wore my airpack at all structure and car fires. I've been retired for 22 years now and still have no health issues. It can be done. Thanks for the video. Glad I retired before the LiPo fire era..
@patricklockerby4308
1 month ago
I was on a safety course over 40 years ago where we were instructed about the dangers of hydrofluoric acid. The acid was being used in the factory to etch glass. It was kept in lead containers because it attacks just about everything else.
The biggest takeaway from that safety course was that hydrofluoric acid causes no pain on first contact. The damage is at first invisible but can be catastrophic. That is why we were instructed that if splashed with even a tiny amount of the acid we were to irrigate it copiously and then go directly to the infirmary.
@MrVeryCranky
1 month ago
Hydrofluoric acid also causes arrhythmia
@jeffn8218
1 month ago
I work on data center scale power backup systems and in training on lithium ion batteries, we were told to get as far as possible from batteries in thermal runaway because of hydrogen flouride. Everything else was secondary and hydrogen flouride was the primary danger of lithium ion battery fires. That was six years ago. This has been known for a long time. It's surprising it isn't a bigger deal.
@VeteranofthePsychicWars
1 month ago
I interned at a steel mill in college. I and three colleagues got a lung full of blast furnace gas, primarily CO. It felt like someone had wrapped a strap around my chest and used a team of horses to tighten it. Odorless, colorless, and lethal. [note: CO is also emitted from lithium battery offgassing]
@redrider7730
1 month ago
I do not understand the lack of legislation on these, and the fact they are coming utterly unregulated form a country that does not like us.
@Pab-B
1 month ago
This video possibly saved my house and me and my family. We love electric rc cars and have several high-capacity LiPo batteries. I keep them stored in ammo boxes but just learned that they need to be vented to allow for escape of expanding gasses. After watching this, I checked on them and two packs had swollen and broken open. I immediately took them outside and placed them in a metal container and covered them with dry sand. It's sitting on pea gravel in an open area. I will take it to my local county disposal site tomorrow in the bed of my truck. THANK YOU!!!
@JaniceVineyard-kf6wm
1 month ago
That this is being allowed to poisen and kill people is just evil.
@garymalone547
1 month ago
Those jump starter battery packs look lethal.
@boblatzer
1 month ago
3 E bike battery fires in a 24 hr period in Toronto yesterday in hi rise apartments. Unfortunately there are no regulations covering these batteries.
@greenthing99100
1 month ago
I had to use hydrogen fluoride [HF] for preparation of sediment, to remove the silica remains of diatoms, during my Ph D research nearly 50 years ago. It scared the living daylights out of me then and still does. Do not breathe anything that looks like smoke coming from any appliance containing lithium ion batteries; it isn't smoke in any conventional sense; it is a cloud of more or less toxic vapours and gases and particulates. The rule in my lab was simple - smoke or vapour of any sort, press the fire alarm, make sure all your colleagues are out of the lab. - drag them if necessary. Signage outside warned first responders. Stay out, no matter how important the thing you just remembered, it is not worth dying for. If the vapour touched your skin or clothes, don't be shy, strip them off and wash down with the shower provided for the purpose, until someone tells you to stop so they can take you to hospital for assessment. HF will form hydrofluoric acid with any moisture including sweat and will pass into the body through skin. Shudder...
@greenthing99100
1 month ago
@VariantAEC HF and hydrofluoric acid cause deep skin burns and bone damage, enter the blood and bind with calcium and magnesium causing hypocalcemia. Dilute solutions are dangerous because the surface may not hurt for a day or two while underneath it is causing severe damage. Even small splashes may lead to cardiac arrest and seizures. Breathing in HF creates acid directly in the respiratory tract and lung tissue causing unsurvivable damage. Guaranteed HF and hydrofluoric acid proof whole body personal protective equipment including breathing apparatus is essential to avoid exposure. Calcium gluconate is used in treatment but will not prevent or reverse damage so exposure should be avoided. Long-term damage is not much of a risk if you are dead, and even if you survive, lifelong long term scarring, disability and pain may continue indefinitely.
@michaelk7111
1 month ago
Nothing is more irritating to me as watching fire scene videos with fire personnel working a fire without their SCBA gear in use. In today's world you have no idea what is in smoke, or what particles are floating in the air after a fire (asbestos is one). I'm known to pull folks off the line and have them properly gear up, even my chief has gotten an earful from me.. You only have one set of lungs, take good care of them, and save the macho stuff for something else...
@davidbeem184
1 month ago
This is so far from "green"!
@marcusjones1088
1 month ago (edited)
The Sweedish military identified the gases from LFP and NMC batteries in TR. Chemicals found were similar to chemical warfare agents. HF is only part of the cocktail. SCBA is vital.
@brianm9962
1 month ago
I am sharing this with my model club as we use LiPo batteries almost exclusively, we dispose of old ones by discharging them, puncture them and placing into salty water. I didn't know the fumes could be so dangerous to health. Thank you.
@just-incase
1 month ago
Counterfeit products can sneak into the country. It's all the more concerning to think of how many shipping containers might have products with lithium battery packs inside, legitimately built to standards or not. Sigh, human lungs are precious!
@ainerush8942
1 month ago
Hi pat. I live in ireland and i'm so grateful to you for talking about these incidents. I live in the north and the police began a 'crackdown' on e- scooters and e-bikes being illegally used on public roads. There were pics uploaded of a lot of them and a post saying they would be destroyed. The psni,police service of ni, are not the best on health and safety so i hope the fire service are liasing with them to advise on storage safety etc. So many people are using e- transport and charging and storing them inside homes ,in rows of densely populated residential areas. Many houses of multiple occupancy have had e fires and residents have no control over what other residents bring inside the hmo. I believe that a public awareness and exposé should be done in every country. These e batteries and rechareable items are potential killers and people just are not aware of the risk. A family of 8 children and two parents were almost killed in an e-bike charging incident. The battery was charging in the garage and started a fire which caused an explosion and the fire ripped through the home. The family were left homeless but healthy. It was a christmas gift and the community rallied,a rental home was offered and toys ,gifts and replacements for
everything they had lost that could be replaced ,were offered to the family. Thank goodness everyone got out,stayed well away from the fire and their lives as well as their christmas were saved.❤
@carlosgarrido4916
1 month ago
They sold us the safety of electric cars, liars
@garydargan6
1 month ago
I used to use HF at work in a dedicated fume cupboard which had a high face velocity to ensure removal of fumes. We were extremely vigilant on PPE. Wearing both safety glasses and face shields and using a plastic apron and triple gloving. We also has an emergency kit with neutralising gels containing calcium, Calcium tablet and ampoules of injectable calcium gluconate. The kit was packed with instructions to go with the patient to hospital after immediate first aid treatment. This included a recommendation to supplement magnesium intravenously. Apparently the acid also upsets the balance between calcium and magnesium in the bloodstream and can stop the heart as a result. Luckily we only had a couple of near misses because we were extremely vigilant. We had a colleague who spilt some on a small area of his thigh in his backyard lab. He dove straight into his swimming pool and called an ambulance. Unfortunately the hospital treated it as a normal acid burn and he died a few days later.
@rosswagner3021
1 month ago
Pat I am so glad you have this channel and you are willing to share your knowledge, you are awesome. I especially like when you share this information on batteries because this involves everyone and until I started watching your channel I did not realize how important it is to have this information and to be able to share it with others. I have passed on a lot of the things you have shared and about you channel because I feel it's that important for people to have this awareness. Thank you again.
@stevejagger8602
1 month ago
When I started watching your channel I searched for off gas products from Li ion battery in thermal runaway.
As soon as I saw Hydrogen Fluoride in the list it raised the alarm because I knew that breathed into the lungs it would form hydrofluoric acid - one of the most dangerous and corrosive acids, used to etch glass.
We urgently need more public information about the dangers posed by lithium (and sodium) batteries.
@YanestraAgain
1 month ago
HF is a catastrophe for the human body. It slowly kills you without telling you first.
@Armor_Strike
1 month ago
It is very unfortunate that the media fails to inform the public about the toxic fumes from batteries, as this poses a deadly threat to life and health
@edwarddavila3363
1 month ago
Pat, I appreciate the effort in making these videos. I am on the Haz Mat team at our fire department. Your videos help understand at FF level the challenges we all face. Presently, when we make any entry into a hot zone. Especially EV fires, we apply Flourine paper to our face mask. If I understood correctly, your saying the Flourine is so reactive, our monitors and F paper would not detect it. Is that for smaller batteries or all batteries. Thank you again. Your site provide me all sorts of information to help with all the challenges.
Ed
@Retrogamer71
1 month ago
Hydrogen Fluoride risk of death from battery fire on consumer products is really enough to ban the product on safety grounds.
@KrewOnyx
1 month ago (edited)
This video reminded me of the Illinios State Highway Patrol Ammonia Leak Training video, which has haunted me since watching it at training event over 30 years ago. Other things that have stuck with me from hazmat safety classes during the meth lab craze were to stay away from "methyl ethyl bad sh**," (a reference to part of the name of a family of very deadly chemicals) and "dilution is the solution to the pollution" (fire department washdowns are powerful tools in the hazmat game). I am hopeful that your outreach will help keep something like the Illinois fatal incident from happening again. Love the "Live FD" video shorts. (Seems like something a good-humored cop would produce.) After the second one I recognized them as outstanding parodies. Firefighters have some great senses of humor. A Batallion Chief shared some good jokes with me two careers ago, in between serious moments, when I was a reporter at his incidents.
@paultranchell8927
1 month ago
As an Industrial Hygienist, I took a deep breath at the mention of HF. Yikes. An earlier video mentioned a study of chemical exposures from EV fires. I have been watching with anticipation for results. Love your videos.
@AndrewZonenberg
1 month ago (edited)
Early recognition and treatment of HF inhalation injuries makes a big difference in outcomes.
See Zierold, Dustin, and Matthew Chauviere. "Hydrogen fluoride inhalation injury because of a fire suppression system." Military medicine 177.1 (2012): 108-112.
This paper is specifically about fluorinated fire suppression agent tanks (like FM-200) being hit by plasma jets from RPGs in combat, so totally different mechanism of generation for the HF. But very similar results - minimal external injuries, patient seems fine, then goes into massive and in some cases fatal respiratory failure a bit later. Once they realized what was going on and treated the asymptomatic patients after similar RPG hits to the fire extinguisher in the future, outcomes improved dramatically.
@jazzandbluesculturalheritage
1 month ago
OMG! THIS IS FOOKING SCARY! NOW I UNDERSTAND WHY AIRLINES ARE ASKING WHETHER YOU ARE CARRYING LITHIUM-ION BATTERIES! GEEZ! PASSENGERS CAN BE KILLED BY THE FAILURES OF OTHERS WHO LIE! SCARY SCARY SCARY!
@aspensulphate
1 month ago
EV and E-bike manufacturers have built a huge industry on this vile, unpredictable battery technology. A safer, more stable battery is needed more than ever.
@JustPeasant
1 month ago
1) How much of a gasses these men inhale?
2) Considering no responses from governing bodies around the world on Lithium-Ion batteries safety: Are we dealing with Lithium-Ion batteries cartel?
@karyncremeens9376
1 month ago
One would hope some the research and development dollars being siphoned off would have are should be going toward increasing the protection and safety of our fire and rescue personnel.
@johnsmit5999
1 month ago
That is a lot of damage in a very short time.
@wendywaddell-hardy9853
1 month ago (edited)
I had a leaf blower. I was careful to charge it and to unplug it as soon as it charged. TWICE the battery OFF the charger, it's light showing it is charging turned on all by itself! It happened in the winter and I live in a place where I don't turn the heater on. I took it back to ACE and explained what happened. I was never told the reason. I prefer a plug in blower now, even though it is a pain. Just don't trust lithium ion batteries.
@exzactlyy
1 month ago
Another reason HF doesn't show up in the gas data for many battery fire tests is because tests like UL9540A are looking at flammability hazards rather than toxic exposure. So HF often isn't reported at all. Newer testing requirements are changing that
@cloud-dragon
1 month ago (edited)
1:38 Additional to fluoride in the batteries - many compressors today use PTFE sealing, and when PTFE is burning - a nasty gas is emitted which can cause all kinds of health hazards - teflon flu, etc...
@robbobtheplucker3082
1 month ago
How can they even put this crap out there without a UL listings?????? Should be ILLEGAL and people should be held severely accountable especially with the risk and Injuries we keep seeing and hearing about!!!! Because of the $$$$ grabbers [ you know our elected officials] this is going to be more common!!!!
@kruelunusual6242
1 month ago
These fires should have their own classification and required training!
@Truckngirl
1 month ago
Police are first responders, too. And they don't have any breathing apparatus on hand to protect them. It's crucial that departments worldwide are educated on these hazards. My brother is a patrol officer in Hawaii. I am the one educating him. His department has no policy, education or training for EV and lithium ion battery thermal runaway. There are a HUGE amount of electric vehicles here (bikes, E motorcycles, and scooters), most ridden by children. Not to mention the plethora of EV cars and trucks. It's a bad situation.
@hungarianaustralian
1 month ago
No way???? This is MADNESS!!!!
@michaeljohnson4947
1 month ago
ban lithium ion batteries
@voranartsirisubsoontorn
1 month ago
Do they have good enough filter mask?
@lesliepropheter5040
1 month ago
If you are on an airplane and someone's battery goes off... the cheaper ones are the most volatile of course.
@PaulC-pm3ub
1 month ago
Hydroflouric acid can't be stored in glass bottles because it dissolves them. We were warned in Chemistry class that any contact with skin is followed by deeper damage (and it can go very deep). These batteries need to be banned, no matter how useful they are.
@debbyrogers3722
1 month ago
Thank you for warning us! These dangerous batteries why aren't they banned?
@GladysBailey777
1 month ago
Why are they legal?
@EveryDayCompute
1 month ago
I am thinking we should have mandatory labeling of what gases will be emitted if something burns so people have that info
@jimbrewer2893
1 month ago
It's disturbing to me to see videos of firefighters not wearing SCBA on the job. Especially with so many suffering cancer and other health problems. Retired VFF/EMT.
@zfloflo
1 month ago
It may be worth to have a systematic survey of ALL firefighters involved with Li ion incident. The results may be unsettling.
@paulh6395
1 month ago
The agenda is much more profitable than peoples lives .
@TheRustyLM
1 month ago
Would love a website database of battery fires, national and worldwide.
@drzeng-ie8eb
1 month ago (edited)
How many people have to die before these Lithium batteries are Ban .
@drzeng-ie8eb
1 month ago
Lithium batteries are extremely dangerous and are toxic bombs. They should be BAN worldwide before they poison our Environment
@dpose6525
1 month ago
Do you have a simple video we can all send to our family members who know nothing about the dangers of these batteries and what to in a thermal runaway situation
@skdsky0
1 month ago (edited)
I had a 50lb lifepo4 (one of the safest chemistry!!) battery blow up and got a lung full of the smoke, + an additional 3 minutes of exposure as I dragged the flaming pack outside. ... Lungs Immediately burned for hours, and I felt strangely unwell for the whole day. It's been now months, and fortunately didn't die. Probably caused permanent damage to something I can't see. Would NOT recommend... Do everything you can to make sure if a pack catches fire it's not around anything AND the smoke goes outside.
@jim-t4q
1 month ago
I thought the hydroflouric acid thing was primarily a result of lithium metal batteries exploding? There's been multiple stories of people who have ruined their lungs by breathing a cloud of this from lithium metal battery failures
@silent1967
1 month ago (edited)
I would say after watching Pat talk about so many of these ( it should only take one report though ) that everyone should have some type of portable air supply to use ( in their home, garage or shop ) if they have to deal with these batteries. Other than that just GET OUT and let it burn.
@randomidiot8142
1 month ago
It didn't take that long for r12 to be replaced. How many people need to die before we stop pushing these li's?
@DeeDee-pw9pm
1 month ago
I have a 12v 2000a battery booster for my car.
Chose it because it only has a small laptop sized (50-80Wh) Li-ion battery while the rest of the capacity is lead-acid.
Li-ion battery capacity is now my #1 consideration when i buy any electrical device with internal power storage.
@tg-zr6iq
1 month ago
A lot of ebikes can be criticaly seized means throw the whole bike out fire extinguisher won't work each cell burns
@andrewjohnson4021
1 month ago
I think a lot of people told them that it was dangerous and unstable and then they used it anyways.
@frankroper3274
1 month ago
I am not a firefighter per se but I tried to get the battery out of a cell phone to re-boot it and it sparked and you have no time to think. It is extremely hot in a flash and you drop it and hope your house doesn't burn down! I know now why they don't want them on planes! Mine did not smoke or give a warning it was just a small battery that was a large hot ball of fire about the size of a bowling ball in a millisecond! Don't mess with them!
@allen423100
1 month ago
dang scary we have 2 E moto bikes and some electric Skate boards most fun iv ever had. but now im thinking if we should get rid of them
@MajorKenshy
1 month ago
Nothing to worry about! This is mostly eco friendly lung damage!
@vladimus9749
1 month ago
I know you've discussed the explosion hazards of lithium iron chemistry. Can you do one on sodium ion hazards?
@crackerede
1 month ago
what I would have wanted to learn is:
how much direct cloud you need to breath in, buts it's hard to do those tests.
I guess that at different stages of battery fires- different gases are released, some require few pufs, some require proper inhale to do damage. The battery chemestry and specific OEM cells are built with a bit different materials, right?
But anyway- see smoke- cover mouth - use proper ppe!
@Ja_Mes
1 month ago
We literally don't need this stuff we lived fine without all this electricity and energy. Sad. And modern humans think theyre smart.
@AndrewChristophersen
1 month ago
Fascinating and very concerning! Is there any treatment (eg a gas ) that can neutralise the acid in the lungs and prevent the ongoing damage ?
@TomTsuji
1 month ago
How about a video on what Civilians can use. Are Filtered Respirators a Safe option - as you attempt to remove a smoking battery to outside the house? Is Holding your breath the Only option?
@dedr4m
1 month ago
Li-Ion battery fires:
Expanding/hot: Hold Breath, Get far away up wind, Begin breathing, Call Emergency.
Exploding: Breathe out, Get far away up wind, Regain breath, Call Emergency.
Those are the safest things to do in both these cases to protect your lungs or reduce chances of injury.
.
If one absolutely has to be around a Lithium fire for even a second, HOLD YA BREATH and DON'T BREATH IN until completely clear from the battery!
In situations such as this, recharge outside where possible, if it begins to thermal runaway, get away from it!
If one is inside and next to a door, especially an open door, if it's looking heated up or swollen Immediately take in a breath BEFORE any fumes are emitted and use as much of that breath to decide to either leave the building or evict the battery from the building, whichever is the safest to do. But once committed, one MUST commit to that decision, no thinking, "Oh, I can just hold my breath and go back in to remove the burning battery", all it takes is for a gag-reflex to open the air-ways for the toxic fumes to enter the lungs and that's not going to be a pleasant experience, survival or not.
Also, once the fumes escape the battery, keep as far and up-stream from the gases as reasonably possible to achieve as little to no exposure.
@TehPwnerer
1 month ago
wonder if inhaling sodium bicarb would be effective postphaxis
@ChristinaAderena
1 month ago
How do we know what things have lithium ion batteries? Is there a comprehensive list
@christiantroy7722
1 month ago
They don't want this information to be public it goes against the net zero bull there trying to ram down your throat you won't see any of this ever mentioned in the News channel
@laurarandolph5600
1 month ago
These operate like a deadly, high tech landmine.
You step on it in your own home by charging your bike, which you assume is a non-deadly eco-friendly transportation vehicle.
And you get a delayed stealth, deadly explosion of your insides.
These things have to be outlawed.
@JimboP-Outside
1 month ago
These videos are very important and I appreciate that you make them so that we're well informed. However, what are we supposed to do? Anything I buy from Amazon, Walmart, Best Buy, you name it has a lithium ion battery in it. Also, you had mentioned in a prior video that the worst place to store them is in the basement. Well, I can't put them in my garage or my shed because both heat up to over 100° in the summer and less than 0° in the winter and my understanding is lithium ion batteries don't like temperature extremes. So what do we do about this and where do we store them? About the only thing I could figure out so far was I buy some fire resistant and explosion resistant bags off of Amazon that are allegedly designed to house these batteries and hopefully reduce the effect of a lithium ion runway. But I have no frigging idea, and I don't know what else to do.
@mikecolby
1 month ago
It just occured to me, when dealing with these smaller packs, what if you were to submerge it in water, say a toilet, sink, or bathtub of water? Wouldn't that solve most issues? Perhaps just need to vent the area ?
@bobclarke5913
1 month ago
Say you have a battery vent in your garage - how long before it's safe to go back in?
Hours, days, years?
@Jon-uj2uw
1 month ago (edited)
I was stuck in a garage with a 30ah 52v ebike battery explosion, the air was completely white my lungs are 100% ok, it's gotta be because of God protecting me or praying about it afterwards either way it was thanks to god
@autodogdact3313
1 month ago
I have 2 sets of recalled handwamers with these batteries. The problem is how do you dispose of them? Nobody takes the recalled ones that I can find.
@Myneckofthewoods7
1 month ago
Are this batteries blowing up due to the extreme heat we are having... if that is the case we have another bigger problem
@iain3411
1 month ago
But there are fake UL listings out there. I'm a retired UL-508A wireman and did all the UL tagging. When the UL inspector comes in and wants to see all our wire because of fake UL markings in the early 2000's . That was back then , how many fake ETL , CSA , UL , CE markings out there ?
@darkseid8481
1 month ago
Funny enough 15 years or 20 years ago my old laptop battery popped but didn't emit smoke just a chemical smell. Maybe a faint smoke for very short time. It was lion
@LoFiNic2025
1 month ago
I couldn't believe firefighters were spraying water on lithium fires? I mean?
@richardmeo2503
1 month ago
Must detox the gear after the fire. Including the SCBA
@imnotusingmyrealname4566
1 month ago
Wow shocked how small the battery was.�� Scary stuff.
@Eduardo_Espinoza
1 month ago
Lead acid batteries have scary warning labels
& these batteries turn into acid in your lungs on contact.
@Milosz_Ostrow
1 month ago
(1:43) A UL mark on an electrical product made in China may be meaningless. Chinese manufacturers are known to forge UL stickers, as I was told years ago by an engineer who worked at UL in Santa Clara, California.
@trevorwilliams1783
1 month ago
Hey Stach I was directly down wind of the spokane fires in the mountains 20-30 miles away. The night that the 600 homes burned my dog got sick and my lungs also experanced the worst pain I have ever felt for them, I got no sleep that night from the lung pain. I am recovered as far as my lungs go but my dog has only been getting worse. Shes very old so I understand to a point but I do have a question. It started out with vomiting and diahrea for her that night and the following days. That got beter however she started to display diabetes like symtoms after this that have only got worse, and some neurological symtoms that have not resloved. What did we breath in from those homes burning?
@drwork2491
1 month ago
People go into hysterics about nuclear power but shrug their shoulders about lithium battery fires. Absolute insanity
@jojobaker1764
1 month ago (edited)
Most of us already knew that these batteries were extremely toxic. Some of us chose to except the risk .I personally I wouldn't own a electric car. And I absolutely wouldn't park one in my garage. And after seeing an electric bike catch fire and the fire department not being able to put it out that ruined my thoughts of buying an electric bike .
@sqr2026
1 month ago
These should be banned as they are dangerous.
@anthonyvalenti9093
1 month ago
How can a non UL battery be sold?
@VictorLarsen-fy9ls
1 month ago
Because manufacturers are silent about the dangers of their products, and new, safer batteries, such as sodium batteries, are not being developed or mass-produced yet. Although sodium battery technology was developed and tested six years ago, they are more fire-safe, only lose part of their charge when damaged, and are less toxic.
These corporations are lobbied by the same people who lobbied for DuPont and other chemical companies involved in scandals.
@wiregold8930
1 month ago (edited)
Fluoride ion, F- , is the most reactive of all common ions.
It's electronegativity is equaled only by cyanide ion, CN- .
@schragervogel8018
1 month ago
Lithium batteries should actually produce an odorant, just like town gas used to because of the carbon monoxide.
@JoeyBlogs007
1 month ago
Do sodium batteries present similar problems during thermal runaway? all be it less likely.
@thomaslabantt6625
1 month ago
THEY WANTED TO BE A FIREMAN AND DIDNT KNOW ITS DANGEROUS ??
@yellingintothewind
1 month ago (edited)
Carbon monoxide is not a major long term threat from this sort of source. It either hits a level to cause acute distress (and is likely lethal within minutes), or it doesn't. The long term prognosis for short duration acute exposure to CO is good. You'll need to replace a bunch of red blood cells, with all the associated issues, but after that you'll probably be fine. It's the metals that will mess you up permanently. Or you HF, that'll do you too. I didn't realize these suckers produced that, yikes.
@InTheGarden1960
1 month ago
Lithium batteries is what brought down mh370. I investigated that accident, just think how bad it was mixing those with salt water. Huge explosion.
@Spiethstar
1 month ago
Wow, that's pretty shocking.
Even with the knowledge, convenience is so hard to counteract that most people won't care about the risk till it's too late.
I'm a bit worried about my mom and her ebike that's in a storage room when she's not using it..
But there isn't a place to put besides there..
Now I know what my mom used to feel when I was testing my bulletproofness all these years..
@mobilecommunicationsnetwor5268
1 month ago
This video discusses the severe health risks associated with lithium-ion battery failures, focusing on a recent incident in Wyoming and medical research regarding lung injuries from toxic vapor inhalation.
Key takeaways:
The Wyoming Incident: A volunteer firefighter named Jack was hospitalized after a SMARTECH jump starter went into thermal runaway (0:00-0:50). Despite quickly moving the device outdoors, he later developed neurological symptoms, vision changes, confusion, and a stutter (0:54-1:13).
Toxic Vapor Hazards: When batteries enter thermal runaway, they release a highly toxic cloud containing carbon monoxide and other hazardous materials (1:16-1:26, 2:06-2:16, 3:15-3:28). The SMARTECH unit involved lacked a UL safety certification (1:39-1:53).
The Danger of Hydrogen Fluoride: A 2026 study from Dublin highlights how hydrogen fluoride gas, released during battery fires, binds with moisture in human airways to form hydrofluoric acid (4:18-4:31). This acid causes severe, often delayed, destruction of lung tissue, as documented in two e-bike battery fire cases (4:47-6:30).
Safety Recommendations: Because the damage from toxic inhalation may not appear immediately (6:31-6:49), the host stresses the importance of using SCBA (Self-Contained Breathing Apparatus) when dealing with any lithium-ion fire, even after the flames are extinguished (7:28-7:44).
@ronfarnsworth7074
1 month ago
What kind of Li batteries or electrolyte release hydrogen flouride?
@billsmith9249
1 month ago
Almost every cell phone uses lithium ion battery.. not sure if those would have the same effect.. what about power tools? I have dozens of Dewalt, Milwaukee, Kobalt, Ryobi batteries. ARe they emitting HF even if they're not on fire? Very scary stuff!
@franksmall1313
1 month ago
GOOD POINT...... LOT'S OF CHEM IN THINGS NOW DAYS. A LITTLE GOES A LONG WAYS. YOU ........ YES YOU . NOT GOING TO GO FAR WITHOUT YOUR LUNGS........... PERIOD.
@hohenzollern6025
1 month ago
Wait, so you are saying even firefighters have no clue how dangerous these are?
Heads should start rolling.
@POOKISTAN
1 month ago
So if you are in an apartment, should you just pull the fire alarm if/when there's a battery that does that so that people in other rooms are not exposed?
@mattcook3671
1 month ago
what is a basic level of filtration that would give even 1 minute of protection here? Is it just a airplane hood or can a AC filter mask get you out?
@mart0225
1 month ago
Are batteries with a CE label safe?
I have a jump starter - air compressor battery combo like in the video. No UL listing. Has a CE label. How should I dispose it?
@MarthaSchleuder
1 month ago
Why were lithium batteries allowed to be sold to consumers to begin with?
@grumpydrummer8960
1 month ago
There must be stricter Fire safety reviews of imported new power storage products being prepared for consumer markets. Strangely current systems. Alot of other Lithium-ion batteries produced for cameras and popular power tools are and have been the most safest with no dangers imposed. Even my own Hearing aids have lithium ion batteries,albeit tiny. Of course the manufacturing of these hazardous versions must come under scrutiny . How are we going to cope when tiny nuclear batteries enter the market, in the future?
@Evsmart-w8n
1 month ago
Trade one pollutant for another. Lithium batteries are highly toxic to people and our environment, a constant fire danger adding one more thing to an all ready polluted environment . EMF Radiation is another concern from these EVs
@ChRoNoS132
1 month ago (edited)
� who's betting her charger/jumpbox/compressor was bought on like Tik-Tox shop or Temu
@Rk_Dark94
1 month ago
Check out not sure what the load was maybe up your alley. Posted 4hrs ago incident from August 11 yesterday. Arkansas: Flatbed Truck Load Falls Off Truck & Catches Fire For HOURS (10x speed)
@StacheDTraining
1 month ago
I'm aware of the incident. It was a Megapack. Is there video out somewhere?
@Rk_Dark94
1 month ago
@StacheDTraining The only video I saw was from that traffic camera time lapse. Video on YouTube with that title from earlier comment
@christophersmith5303
1 month ago
The gases are a serious health threat but wait until we start to see the long-term impacts of the heavy metal nanoparticulates that are emitted in both venting and active fire in thermal runaway. Mutagenic, cytotoxic, carcinogens, genotoxic, and they can cause direct DNA strand breaks - they can pass through your skin, membranes, and of course easily enter your respiratory system and many of them are not readily shed by our bodies. It's going to be much worse than "PFAS"
@doesentmatter
1 month ago
I knew it was an hf injury hf acid can dissolve bone or rocks (silica) pulmonary tissue doesn't stand a chance
@emiliofimbrez1671
1 month ago
And these things are supposed to be safer for the environment?!
@Archangelm127
1 month ago
As if the cancer risk to firefighters from burning artificial materials of all sorts wasn't bad enough... �
@HankPA1
1 month ago
I watch a lot of firefighting videos. It seems that European firefighters are much faster to mask up than Americans.
@fountainvalley100
1 month ago
It's almost like you need to put the charging battery in a dry metal bucket. Next to it is a bucket of water. If it goes into runaway pour the water into the dry bucket and walk away.
Better would be for a company to make a bucket in a bucket. The customer fills the outer bucket with water. The water filled outer bucket would prevent the fire from spreading beyond the bucket.
@ernestyeagley512
1 month ago (edited)
Retired volunteer firefighter here. As long as these batteries are mfg. and available this unfortunate firefighter won't be the last to suffer from these unpredictable and dangerous power sources. Just a matter of time once again there will be a victim (or victims) and another house that burns to the ground. Sadly these lithium ion batteries won't go away, because they mean billions of dollars for the mfg. and for those that sell them (that power lazy kids' means of transportation such as bicycles and scooters). These wholesalers and retailers don't care about public safety. By the way I live near Amish country, and yet have I heard of an Amish child or young Amish adult die from overexertion pedaling a bike or pushing a scooter.
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@anthropicandroid4494
1 month ago
> Hydrogen Flouride
Say no more; if F- were any happier holding that frank negative charge, it would be Noble!
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@Wheresthabeef
1 month ago
This all sounds wonderful. Let's put lithium ion batteries in everything and ban every alternative.
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@Eduardo_Espinoza
1 month ago
EV people gas light people saying that they don't give you lung damage.
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@SalemikTUBE
1 month ago
How are these things legal? We seem to be just accepting that they are in every house and yet they want to ban my gas stove instead.
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@Eduardo_Espinoza
1 month ago
Instant asbestos lungs
So green like a leaf!
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@matthewsocal2540
1 month ago
RUN TO THE SOURCE! No, don't dawn that. Ignore your training. RUSH IN! Dumbfounding in 2026...no?
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@russellhltn1396
1 month ago
I'll bet this battery was bought on Amazon. I overheard the conversation of someone who lost a house to a battery fire. He tried to sue Amazon, but it turns out because Amazon doesn't have a "presence" (a retail store) in any state, they couldn't be sued. Trying to sue the maker (in China) was pointless.
If true, this is a major loophole in the consumer protection laws that needs to be closed. Consumers expect to be protected by consumer laws when they buy something from a US retailer.
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@shockingguy
1 month ago
Wow, this channel does provide some good information
The guy who runs it, Pat
Is an absolute slug at responding or engaging anyone on any of his platforms?
I have sent him private messages about specific questions I had from his videos and all I got was crickets
I'm not impressed with this guy at all. He's definitely full of himself unless he starts to say that he's not by showing that he's not.
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StacheD Training
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2 replies
@Eduardo_Espinoza
1 month ago
So green
so clean
0 emissions
Good for the environment.
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@LoFiNic2025
1 month ago
The whole world becomes TEMU...
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@billsElitetrucking349
1 month ago
I feel sorry for the firefighters that have to deal with these Deadly Lithium batteries.... batteries need to be Ban
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@avlisk
1 month ago
If you had 4 BattleBorn batteries sitting in your bedroom (for backup power during grid outages), would you get rid of them? What kind of battery would you replace them with? I'm thinking of taking the financial hit of $3600, and replacing them with AGM. Advice wanted, and thanks.
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@dave3657
1 month ago
Lithium ion batteries are the new asbestos. �⚰️
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@boerbiet237
1 month ago
Welke opties zijn er (veilig) als je ziet dat het fout gaat? �♂️
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@BryanTorok
1 month ago
I have a friend who tells me that he uses LiFePo4 (Lithium Iron Phosphate) batteries for radio communication backup systems. He claims when used with a proper battery management system (BMS) for charging and discharging they have no chance of catching on fire or going into thermal runaway. Is he correct?
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StacheD Training
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@partidaportet27
1 month ago
Progress? Lithium Ion seems to be a technology we should consign to the garbage
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@romanseleven
1 month ago
Thank you for the sobering information. Due to the lack of reporting on the dangers of EVs and lithium ion batteries, it makes one wonder whether this is part of the depopulation agenda of the powers that be.
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@MapleMAGA1963
1 month ago
It's unfortunate that anyone that seriously tries to get rid of this danger will be attacked by all the ignorant people that think these batteries are saving the planet. Saving the planet one huge open pit mine at a time. That's just the cobalt you don't want to look into the water use to produce lithium.
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@davidhamtaro
1 month ago
What's a little sacrifice compared to saving the "environment" says the "How Dare You" green warriors .
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@barneyrubble9309
1 month ago (edited)
its all safe...trust me im a politician.
Weve put our safety in the hands of Chinese quality control...thats not gonna end well.
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@georgewills-ek1gg
1 month ago
What's with the poem? L0L.
l never trusted any of these dubious "Smartech" things, let alone anything with a lithium ion battery.
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@shortstoryteller-i5p
1 month ago
Hydrogen fluoride. It is one of the toxic gases produced by defective lithium ion batteries. �
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@Aprilsraven629
1 month ago
The law needs to change. Home owners, renters, and businesses need to know this, so a push for mandatory installation of carbon monoxide detectors in every property becomes law along side smoke alarms...
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@Cave5Critter
1 month ago
Lithium-Ion is way too general of an description. I bet is wasn't LiFePO4. Lithium-Ion is what you say if you hate all lithium batteries.
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@leonardkellum6984
1 month ago
Corporate amerika is selling them everywhere, I think they are a terrorists dream come true, and expect arson attacks involving them.
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@AntisocialRedNeckNerd
1 month ago
Lithium-ion batteries are in lots of products. They have become common. The potential danger is not talked about.
How do we know when to dispose of one of these batteries? How do we dispose of a lithium-ion battery correctly?
Ignorance is widespread on this topic. . .
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@matthewphair2469
1 month ago
'Lipo's" of any sort are lethal. I always charge ebike batteries outside. EV's total joke just one in the right place is going to kill hundreds not counting what they are doing to water aquifiers.
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@joescott6469
1 month ago
hear no eval .... speak no eval ....... Government cover up .....
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@solarlaura3355
1 month ago
We are surrounded by LI batteries everywhere we go. I've started carrying painters masks everywhere I go. I will load one for every passenger. If there is a cloud of smoke the masks go on. LI is so dangerous.
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@gerardwood4059
1 month ago
Lithium battery technologies are far more dangerous that the problem they are stupidly trying to solve, climet change.
Man made global warming is a disputed fact, natural global warming is a fact. Absolutely nothing man can do to stop the planet warming, all we can do is not speed it up, but thousands of toxic battery fires is making the air we breath poisonous to us. Time to ban them before the atmosphere is irrevocably made toxic.
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@HML-it7te
1 month ago
It's time we switch to sodium batteries.
Testing with steel rods rammed though them passed the tests.
They say these are much harder to combustion spontaneously.
I'm remember a firefighter in a southern Australian state having exposures resulting in loss of job, severe neurological damage FOR LIFE.
For christs sake, it's not worth it.
The battery industry needs to change over now, not in ten years.
Salt batteries can take much higher and cold-even extreme cold and function with extra wasted heating.
It's a no brainer.
It's also much more environmentally friendly and salt is so plentiful.
But we all know that "environmentally friendly" is just a term for politics.
I'm a retired dual trade (actually triple trade) Electrician Fitter/Mechanic, Linesman and Instrumentation Technician with a keen interest in solar and increasingly battery storage, but not for commercial reasons, only my own personal interest and increasing concerns that unintended consequences for Li battery storage on people's lives.
Home owners and well as Firefighters.
They shouldn't be sacrificed for something that can be changed for the better.
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@khriswildt5633
1 month ago
In other words made in China He's such a blowhard he loves her and himself talk it was made in China
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@georgevanheerden3563
1 month ago
Great pocast! Governments were quick on Covid! No reaction on EV battery fires! Statastical analysis- politicians only reacts positively to who is paying money into their political funds. We need to start using crypto. This will give a better audit trail on the flow of currency!
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@H-River_with_MR
1 month ago (edited)
Be careful with the dual smoke/CO detectors... The proper location is different for both fumes. Smoke goes Up, Carbon Dioxide goes down & will form Carbon Monoxide. Fire detector near the ceilings. CO detectors low on lowest level...
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@josh_gossett
1 month ago
H2OFl= awful if u look at it. Lol
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@josh_gossett
1 month ago
Hydrogen flouride...the thing they give us to drink and call water? Killing people? Nobody else thinks thats odd? I don't think adding oxygen fixes anything just saying
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@FrankFrankston-kj4sx
1 month ago
So who took names at the LA Fires. The largest single turnoff of EVs, Scooters and home batteries in the USA to date?
Answer? No one. This is a repeat. An example of "we learnt nothing!" From ASBESTOS and THALIDOMIDE.
Li-ion Batteries do more than burn.
20 years from now this generation of fire experts aren't going to be looked upon kindly.
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↓
Lithium-Ion Hospitalizes Firefighters
https://yo...↓utu.be/lADLvwAJs-c?si=7r-lrbNNf3K6VDU7
Comments
@mojoneko8303
1 month ago
I was a firefighter for 28 years. I hired on in the mid 70's when SCBA's were first becoming a thing. A lot of the older guys wouldn't use them because the early SCBA's were very heavy and cumbersome. They would give me a hard time for using them. This was near the end of the "Leather Lung" era of Fire Fighting. These guys would come out of a structure fire after extinguishing it looking like they had just got off a shift in a coal mine sit down on the tailboard and light up a cigarette. When I hired on I was told that Fire Fighters typically died within 5 years of retirement. I was determined to beat those odds and wore my airpack at all structure and car fires. I've been retired for 22 years now and still have no health issues. It can be done. Thanks for the video. Glad I retired before the LiPo fire era..
@patricklockerby4308
1 month ago
I was on a safety course over 40 years ago where we were instructed about the dangers of hydrofluoric acid. The acid was being used in the factory to etch glass. It was kept in lead containers because it attacks just about everything else.
The biggest takeaway from that safety course was that hydrofluoric acid causes no pain on first contact. The damage is at first invisible but can be catastrophic. That is why we were instructed that if splashed with even a tiny amount of the acid we were to irrigate it copiously and then go directly to the infirmary.
@MrVeryCranky
1 month ago
Hydrofluoric acid also causes arrhythmia
@jeffn8218
1 month ago
I work on data center scale power backup systems and in training on lithium ion batteries, we were told to get as far as possible from batteries in thermal runaway because of hydrogen flouride. Everything else was secondary and hydrogen flouride was the primary danger of lithium ion battery fires. That was six years ago. This has been known for a long time. It's surprising it isn't a bigger deal.
@VeteranofthePsychicWars
1 month ago
I interned at a steel mill in college. I and three colleagues got a lung full of blast furnace gas, primarily CO. It felt like someone had wrapped a strap around my chest and used a team of horses to tighten it. Odorless, colorless, and lethal. [note: CO is also emitted from lithium battery offgassing]
@redrider7730
1 month ago
I do not understand the lack of legislation on these, and the fact they are coming utterly unregulated form a country that does not like us.
@Pab-B
1 month ago
This video possibly saved my house and me and my family. We love electric rc cars and have several high-capacity LiPo batteries. I keep them stored in ammo boxes but just learned that they need to be vented to allow for escape of expanding gasses. After watching this, I checked on them and two packs had swollen and broken open. I immediately took them outside and placed them in a metal container and covered them with dry sand. It's sitting on pea gravel in an open area. I will take it to my local county disposal site tomorrow in the bed of my truck. THANK YOU!!!
@JaniceVineyard-kf6wm
1 month ago
That this is being allowed to poisen and kill people is just evil.
@garymalone547
1 month ago
Those jump starter battery packs look lethal.
@boblatzer
1 month ago
3 E bike battery fires in a 24 hr period in Toronto yesterday in hi rise apartments. Unfortunately there are no regulations covering these batteries.
@greenthing99100
1 month ago
I had to use hydrogen fluoride [HF] for preparation of sediment, to remove the silica remains of diatoms, during my Ph D research nearly 50 years ago. It scared the living daylights out of me then and still does. Do not breathe anything that looks like smoke coming from any appliance containing lithium ion batteries; it isn't smoke in any conventional sense; it is a cloud of more or less toxic vapours and gases and particulates. The rule in my lab was simple - smoke or vapour of any sort, press the fire alarm, make sure all your colleagues are out of the lab. - drag them if necessary. Signage outside warned first responders. Stay out, no matter how important the thing you just remembered, it is not worth dying for. If the vapour touched your skin or clothes, don't be shy, strip them off and wash down with the shower provided for the purpose, until someone tells you to stop so they can take you to hospital for assessment. HF will form hydrofluoric acid with any moisture including sweat and will pass into the body through skin. Shudder...
@greenthing99100
1 month ago
@VariantAEC HF and hydrofluoric acid cause deep skin burns and bone damage, enter the blood and bind with calcium and magnesium causing hypocalcemia. Dilute solutions are dangerous because the surface may not hurt for a day or two while underneath it is causing severe damage. Even small splashes may lead to cardiac arrest and seizures. Breathing in HF creates acid directly in the respiratory tract and lung tissue causing unsurvivable damage. Guaranteed HF and hydrofluoric acid proof whole body personal protective equipment including breathing apparatus is essential to avoid exposure. Calcium gluconate is used in treatment but will not prevent or reverse damage so exposure should be avoided. Long-term damage is not much of a risk if you are dead, and even if you survive, lifelong long term scarring, disability and pain may continue indefinitely.
@michaelk7111
1 month ago
Nothing is more irritating to me as watching fire scene videos with fire personnel working a fire without their SCBA gear in use. In today's world you have no idea what is in smoke, or what particles are floating in the air after a fire (asbestos is one). I'm known to pull folks off the line and have them properly gear up, even my chief has gotten an earful from me.. You only have one set of lungs, take good care of them, and save the macho stuff for something else...
@davidbeem184
1 month ago
This is so far from "green"!
@marcusjones1088
1 month ago (edited)
The Sweedish military identified the gases from LFP and NMC batteries in TR. Chemicals found were similar to chemical warfare agents. HF is only part of the cocktail. SCBA is vital.
@brianm9962
1 month ago
I am sharing this with my model club as we use LiPo batteries almost exclusively, we dispose of old ones by discharging them, puncture them and placing into salty water. I didn't know the fumes could be so dangerous to health. Thank you.
@just-incase
1 month ago
Counterfeit products can sneak into the country. It's all the more concerning to think of how many shipping containers might have products with lithium battery packs inside, legitimately built to standards or not. Sigh, human lungs are precious!
@ainerush8942
1 month ago
Hi pat. I live in ireland and i'm so grateful to you for talking about these incidents. I live in the north and the police began a 'crackdown' on e- scooters and e-bikes being illegally used on public roads. There were pics uploaded of a lot of them and a post saying they would be destroyed. The psni,police service of ni, are not the best on health and safety so i hope the fire service are liasing with them to advise on storage safety etc. So many people are using e- transport and charging and storing them inside homes ,in rows of densely populated residential areas. Many houses of multiple occupancy have had e fires and residents have no control over what other residents bring inside the hmo. I believe that a public awareness and exposé should be done in every country. These e batteries and rechareable items are potential killers and people just are not aware of the risk. A family of 8 children and two parents were almost killed in an e-bike charging incident. The battery was charging in the garage and started a fire which caused an explosion and the fire ripped through the home. The family were left homeless but healthy. It was a christmas gift and the community rallied,a rental home was offered and toys ,gifts and replacements for
everything they had lost that could be replaced ,were offered to the family. Thank goodness everyone got out,stayed well away from the fire and their lives as well as their christmas were saved.❤
@carlosgarrido4916
1 month ago
They sold us the safety of electric cars, liars
@garydargan6
1 month ago
I used to use HF at work in a dedicated fume cupboard which had a high face velocity to ensure removal of fumes. We were extremely vigilant on PPE. Wearing both safety glasses and face shields and using a plastic apron and triple gloving. We also has an emergency kit with neutralising gels containing calcium, Calcium tablet and ampoules of injectable calcium gluconate. The kit was packed with instructions to go with the patient to hospital after immediate first aid treatment. This included a recommendation to supplement magnesium intravenously. Apparently the acid also upsets the balance between calcium and magnesium in the bloodstream and can stop the heart as a result. Luckily we only had a couple of near misses because we were extremely vigilant. We had a colleague who spilt some on a small area of his thigh in his backyard lab. He dove straight into his swimming pool and called an ambulance. Unfortunately the hospital treated it as a normal acid burn and he died a few days later.
@rosswagner3021
1 month ago
Pat I am so glad you have this channel and you are willing to share your knowledge, you are awesome. I especially like when you share this information on batteries because this involves everyone and until I started watching your channel I did not realize how important it is to have this information and to be able to share it with others. I have passed on a lot of the things you have shared and about you channel because I feel it's that important for people to have this awareness. Thank you again.
@stevejagger8602
1 month ago
When I started watching your channel I searched for off gas products from Li ion battery in thermal runaway.
As soon as I saw Hydrogen Fluoride in the list it raised the alarm because I knew that breathed into the lungs it would form hydrofluoric acid - one of the most dangerous and corrosive acids, used to etch glass.
We urgently need more public information about the dangers posed by lithium (and sodium) batteries.
@YanestraAgain
1 month ago
HF is a catastrophe for the human body. It slowly kills you without telling you first.
@Armor_Strike
1 month ago
It is very unfortunate that the media fails to inform the public about the toxic fumes from batteries, as this poses a deadly threat to life and health
@edwarddavila3363
1 month ago
Pat, I appreciate the effort in making these videos. I am on the Haz Mat team at our fire department. Your videos help understand at FF level the challenges we all face. Presently, when we make any entry into a hot zone. Especially EV fires, we apply Flourine paper to our face mask. If I understood correctly, your saying the Flourine is so reactive, our monitors and F paper would not detect it. Is that for smaller batteries or all batteries. Thank you again. Your site provide me all sorts of information to help with all the challenges.
Ed
@Retrogamer71
1 month ago
Hydrogen Fluoride risk of death from battery fire on consumer products is really enough to ban the product on safety grounds.
@KrewOnyx
1 month ago (edited)
This video reminded me of the Illinios State Highway Patrol Ammonia Leak Training video, which has haunted me since watching it at training event over 30 years ago. Other things that have stuck with me from hazmat safety classes during the meth lab craze were to stay away from "methyl ethyl bad sh**," (a reference to part of the name of a family of very deadly chemicals) and "dilution is the solution to the pollution" (fire department washdowns are powerful tools in the hazmat game). I am hopeful that your outreach will help keep something like the Illinois fatal incident from happening again. Love the "Live FD" video shorts. (Seems like something a good-humored cop would produce.) After the second one I recognized them as outstanding parodies. Firefighters have some great senses of humor. A Batallion Chief shared some good jokes with me two careers ago, in between serious moments, when I was a reporter at his incidents.
@paultranchell8927
1 month ago
As an Industrial Hygienist, I took a deep breath at the mention of HF. Yikes. An earlier video mentioned a study of chemical exposures from EV fires. I have been watching with anticipation for results. Love your videos.
@AndrewZonenberg
1 month ago (edited)
Early recognition and treatment of HF inhalation injuries makes a big difference in outcomes.
See Zierold, Dustin, and Matthew Chauviere. "Hydrogen fluoride inhalation injury because of a fire suppression system." Military medicine 177.1 (2012): 108-112.
This paper is specifically about fluorinated fire suppression agent tanks (like FM-200) being hit by plasma jets from RPGs in combat, so totally different mechanism of generation for the HF. But very similar results - minimal external injuries, patient seems fine, then goes into massive and in some cases fatal respiratory failure a bit later. Once they realized what was going on and treated the asymptomatic patients after similar RPG hits to the fire extinguisher in the future, outcomes improved dramatically.
@jazzandbluesculturalheritage
1 month ago
OMG! THIS IS FOOKING SCARY! NOW I UNDERSTAND WHY AIRLINES ARE ASKING WHETHER YOU ARE CARRYING LITHIUM-ION BATTERIES! GEEZ! PASSENGERS CAN BE KILLED BY THE FAILURES OF OTHERS WHO LIE! SCARY SCARY SCARY!
@aspensulphate
1 month ago
EV and E-bike manufacturers have built a huge industry on this vile, unpredictable battery technology. A safer, more stable battery is needed more than ever.
@JustPeasant
1 month ago
1) How much of a gasses these men inhale?
2) Considering no responses from governing bodies around the world on Lithium-Ion batteries safety: Are we dealing with Lithium-Ion batteries cartel?
@karyncremeens9376
1 month ago
One would hope some the research and development dollars being siphoned off would have are should be going toward increasing the protection and safety of our fire and rescue personnel.
@johnsmit5999
1 month ago
That is a lot of damage in a very short time.
@wendywaddell-hardy9853
1 month ago (edited)
I had a leaf blower. I was careful to charge it and to unplug it as soon as it charged. TWICE the battery OFF the charger, it's light showing it is charging turned on all by itself! It happened in the winter and I live in a place where I don't turn the heater on. I took it back to ACE and explained what happened. I was never told the reason. I prefer a plug in blower now, even though it is a pain. Just don't trust lithium ion batteries.
@exzactlyy
1 month ago
Another reason HF doesn't show up in the gas data for many battery fire tests is because tests like UL9540A are looking at flammability hazards rather than toxic exposure. So HF often isn't reported at all. Newer testing requirements are changing that
@cloud-dragon
1 month ago (edited)
1:38 Additional to fluoride in the batteries - many compressors today use PTFE sealing, and when PTFE is burning - a nasty gas is emitted which can cause all kinds of health hazards - teflon flu, etc...
@robbobtheplucker3082
1 month ago
How can they even put this crap out there without a UL listings?????? Should be ILLEGAL and people should be held severely accountable especially with the risk and Injuries we keep seeing and hearing about!!!! Because of the $$$$ grabbers [ you know our elected officials] this is going to be more common!!!!
@kruelunusual6242
1 month ago
These fires should have their own classification and required training!
@Truckngirl
1 month ago
Police are first responders, too. And they don't have any breathing apparatus on hand to protect them. It's crucial that departments worldwide are educated on these hazards. My brother is a patrol officer in Hawaii. I am the one educating him. His department has no policy, education or training for EV and lithium ion battery thermal runaway. There are a HUGE amount of electric vehicles here (bikes, E motorcycles, and scooters), most ridden by children. Not to mention the plethora of EV cars and trucks. It's a bad situation.
@hungarianaustralian
1 month ago
No way???? This is MADNESS!!!!
@michaeljohnson4947
1 month ago
ban lithium ion batteries
@voranartsirisubsoontorn
1 month ago
Do they have good enough filter mask?
@lesliepropheter5040
1 month ago
If you are on an airplane and someone's battery goes off... the cheaper ones are the most volatile of course.
@PaulC-pm3ub
1 month ago
Hydroflouric acid can't be stored in glass bottles because it dissolves them. We were warned in Chemistry class that any contact with skin is followed by deeper damage (and it can go very deep). These batteries need to be banned, no matter how useful they are.
@debbyrogers3722
1 month ago
Thank you for warning us! These dangerous batteries why aren't they banned?
@GladysBailey777
1 month ago
Why are they legal?
@EveryDayCompute
1 month ago
I am thinking we should have mandatory labeling of what gases will be emitted if something burns so people have that info
@jimbrewer2893
1 month ago
It's disturbing to me to see videos of firefighters not wearing SCBA on the job. Especially with so many suffering cancer and other health problems. Retired VFF/EMT.
@zfloflo
1 month ago
It may be worth to have a systematic survey of ALL firefighters involved with Li ion incident. The results may be unsettling.
@paulh6395
1 month ago
The agenda is much more profitable than peoples lives .
@TheRustyLM
1 month ago
Would love a website database of battery fires, national and worldwide.
@drzeng-ie8eb
1 month ago (edited)
How many people have to die before these Lithium batteries are Ban .
@drzeng-ie8eb
1 month ago
Lithium batteries are extremely dangerous and are toxic bombs. They should be BAN worldwide before they poison our Environment
@dpose6525
1 month ago
Do you have a simple video we can all send to our family members who know nothing about the dangers of these batteries and what to in a thermal runaway situation
@skdsky0
1 month ago (edited)
I had a 50lb lifepo4 (one of the safest chemistry!!) battery blow up and got a lung full of the smoke, + an additional 3 minutes of exposure as I dragged the flaming pack outside. ... Lungs Immediately burned for hours, and I felt strangely unwell for the whole day. It's been now months, and fortunately didn't die. Probably caused permanent damage to something I can't see. Would NOT recommend... Do everything you can to make sure if a pack catches fire it's not around anything AND the smoke goes outside.
@jim-t4q
1 month ago
I thought the hydroflouric acid thing was primarily a result of lithium metal batteries exploding? There's been multiple stories of people who have ruined their lungs by breathing a cloud of this from lithium metal battery failures
@silent1967
1 month ago (edited)
I would say after watching Pat talk about so many of these ( it should only take one report though ) that everyone should have some type of portable air supply to use ( in their home, garage or shop ) if they have to deal with these batteries. Other than that just GET OUT and let it burn.
@randomidiot8142
1 month ago
It didn't take that long for r12 to be replaced. How many people need to die before we stop pushing these li's?
@DeeDee-pw9pm
1 month ago
I have a 12v 2000a battery booster for my car.
Chose it because it only has a small laptop sized (50-80Wh) Li-ion battery while the rest of the capacity is lead-acid.
Li-ion battery capacity is now my #1 consideration when i buy any electrical device with internal power storage.
@tg-zr6iq
1 month ago
A lot of ebikes can be criticaly seized means throw the whole bike out fire extinguisher won't work each cell burns
@andrewjohnson4021
1 month ago
I think a lot of people told them that it was dangerous and unstable and then they used it anyways.
@frankroper3274
1 month ago
I am not a firefighter per se but I tried to get the battery out of a cell phone to re-boot it and it sparked and you have no time to think. It is extremely hot in a flash and you drop it and hope your house doesn't burn down! I know now why they don't want them on planes! Mine did not smoke or give a warning it was just a small battery that was a large hot ball of fire about the size of a bowling ball in a millisecond! Don't mess with them!
@allen423100
1 month ago
dang scary we have 2 E moto bikes and some electric Skate boards most fun iv ever had. but now im thinking if we should get rid of them
@MajorKenshy
1 month ago
Nothing to worry about! This is mostly eco friendly lung damage!
@vladimus9749
1 month ago
I know you've discussed the explosion hazards of lithium iron chemistry. Can you do one on sodium ion hazards?
@crackerede
1 month ago
what I would have wanted to learn is:
how much direct cloud you need to breath in, buts it's hard to do those tests.
I guess that at different stages of battery fires- different gases are released, some require few pufs, some require proper inhale to do damage. The battery chemestry and specific OEM cells are built with a bit different materials, right?
But anyway- see smoke- cover mouth - use proper ppe!
@Ja_Mes
1 month ago
We literally don't need this stuff we lived fine without all this electricity and energy. Sad. And modern humans think theyre smart.
@AndrewChristophersen
1 month ago
Fascinating and very concerning! Is there any treatment (eg a gas ) that can neutralise the acid in the lungs and prevent the ongoing damage ?
@TomTsuji
1 month ago
How about a video on what Civilians can use. Are Filtered Respirators a Safe option - as you attempt to remove a smoking battery to outside the house? Is Holding your breath the Only option?
@dedr4m
1 month ago
Li-Ion battery fires:
Expanding/hot: Hold Breath, Get far away up wind, Begin breathing, Call Emergency.
Exploding: Breathe out, Get far away up wind, Regain breath, Call Emergency.
Those are the safest things to do in both these cases to protect your lungs or reduce chances of injury.
.
If one absolutely has to be around a Lithium fire for even a second, HOLD YA BREATH and DON'T BREATH IN until completely clear from the battery!
In situations such as this, recharge outside where possible, if it begins to thermal runaway, get away from it!
If one is inside and next to a door, especially an open door, if it's looking heated up or swollen Immediately take in a breath BEFORE any fumes are emitted and use as much of that breath to decide to either leave the building or evict the battery from the building, whichever is the safest to do. But once committed, one MUST commit to that decision, no thinking, "Oh, I can just hold my breath and go back in to remove the burning battery", all it takes is for a gag-reflex to open the air-ways for the toxic fumes to enter the lungs and that's not going to be a pleasant experience, survival or not.
Also, once the fumes escape the battery, keep as far and up-stream from the gases as reasonably possible to achieve as little to no exposure.
@TehPwnerer
1 month ago
wonder if inhaling sodium bicarb would be effective postphaxis
@ChristinaAderena
1 month ago
How do we know what things have lithium ion batteries? Is there a comprehensive list
@christiantroy7722
1 month ago
They don't want this information to be public it goes against the net zero bull there trying to ram down your throat you won't see any of this ever mentioned in the News channel
@laurarandolph5600
1 month ago
These operate like a deadly, high tech landmine.
You step on it in your own home by charging your bike, which you assume is a non-deadly eco-friendly transportation vehicle.
And you get a delayed stealth, deadly explosion of your insides.
These things have to be outlawed.
@JimboP-Outside
1 month ago
These videos are very important and I appreciate that you make them so that we're well informed. However, what are we supposed to do? Anything I buy from Amazon, Walmart, Best Buy, you name it has a lithium ion battery in it. Also, you had mentioned in a prior video that the worst place to store them is in the basement. Well, I can't put them in my garage or my shed because both heat up to over 100° in the summer and less than 0° in the winter and my understanding is lithium ion batteries don't like temperature extremes. So what do we do about this and where do we store them? About the only thing I could figure out so far was I buy some fire resistant and explosion resistant bags off of Amazon that are allegedly designed to house these batteries and hopefully reduce the effect of a lithium ion runway. But I have no frigging idea, and I don't know what else to do.
@mikecolby
1 month ago
It just occured to me, when dealing with these smaller packs, what if you were to submerge it in water, say a toilet, sink, or bathtub of water? Wouldn't that solve most issues? Perhaps just need to vent the area ?
@bobclarke5913
1 month ago
Say you have a battery vent in your garage - how long before it's safe to go back in?
Hours, days, years?
@Jon-uj2uw
1 month ago (edited)
I was stuck in a garage with a 30ah 52v ebike battery explosion, the air was completely white my lungs are 100% ok, it's gotta be because of God protecting me or praying about it afterwards either way it was thanks to god
@autodogdact3313
1 month ago
I have 2 sets of recalled handwamers with these batteries. The problem is how do you dispose of them? Nobody takes the recalled ones that I can find.
@Myneckofthewoods7
1 month ago
Are this batteries blowing up due to the extreme heat we are having... if that is the case we have another bigger problem
@iain3411
1 month ago
But there are fake UL listings out there. I'm a retired UL-508A wireman and did all the UL tagging. When the UL inspector comes in and wants to see all our wire because of fake UL markings in the early 2000's . That was back then , how many fake ETL , CSA , UL , CE markings out there ?
@darkseid8481
1 month ago
Funny enough 15 years or 20 years ago my old laptop battery popped but didn't emit smoke just a chemical smell. Maybe a faint smoke for very short time. It was lion
@LoFiNic2025
1 month ago
I couldn't believe firefighters were spraying water on lithium fires? I mean?
@richardmeo2503
1 month ago
Must detox the gear after the fire. Including the SCBA
@imnotusingmyrealname4566
1 month ago
Wow shocked how small the battery was.�� Scary stuff.
@Eduardo_Espinoza
1 month ago
Lead acid batteries have scary warning labels
& these batteries turn into acid in your lungs on contact.
@Milosz_Ostrow
1 month ago
(1:43) A UL mark on an electrical product made in China may be meaningless. Chinese manufacturers are known to forge UL stickers, as I was told years ago by an engineer who worked at UL in Santa Clara, California.
@trevorwilliams1783
1 month ago
Hey Stach I was directly down wind of the spokane fires in the mountains 20-30 miles away. The night that the 600 homes burned my dog got sick and my lungs also experanced the worst pain I have ever felt for them, I got no sleep that night from the lung pain. I am recovered as far as my lungs go but my dog has only been getting worse. Shes very old so I understand to a point but I do have a question. It started out with vomiting and diahrea for her that night and the following days. That got beter however she started to display diabetes like symtoms after this that have only got worse, and some neurological symtoms that have not resloved. What did we breath in from those homes burning?
@drwork2491
1 month ago
People go into hysterics about nuclear power but shrug their shoulders about lithium battery fires. Absolute insanity
@jojobaker1764
1 month ago (edited)
Most of us already knew that these batteries were extremely toxic. Some of us chose to except the risk .I personally I wouldn't own a electric car. And I absolutely wouldn't park one in my garage. And after seeing an electric bike catch fire and the fire department not being able to put it out that ruined my thoughts of buying an electric bike .
@sqr2026
1 month ago
These should be banned as they are dangerous.
@anthonyvalenti9093
1 month ago
How can a non UL battery be sold?
@VictorLarsen-fy9ls
1 month ago
Because manufacturers are silent about the dangers of their products, and new, safer batteries, such as sodium batteries, are not being developed or mass-produced yet. Although sodium battery technology was developed and tested six years ago, they are more fire-safe, only lose part of their charge when damaged, and are less toxic.
These corporations are lobbied by the same people who lobbied for DuPont and other chemical companies involved in scandals.
@wiregold8930
1 month ago (edited)
Fluoride ion, F- , is the most reactive of all common ions.
It's electronegativity is equaled only by cyanide ion, CN- .
@schragervogel8018
1 month ago
Lithium batteries should actually produce an odorant, just like town gas used to because of the carbon monoxide.
@JoeyBlogs007
1 month ago
Do sodium batteries present similar problems during thermal runaway? all be it less likely.
@thomaslabantt6625
1 month ago
THEY WANTED TO BE A FIREMAN AND DIDNT KNOW ITS DANGEROUS ??
@yellingintothewind
1 month ago (edited)
Carbon monoxide is not a major long term threat from this sort of source. It either hits a level to cause acute distress (and is likely lethal within minutes), or it doesn't. The long term prognosis for short duration acute exposure to CO is good. You'll need to replace a bunch of red blood cells, with all the associated issues, but after that you'll probably be fine. It's the metals that will mess you up permanently. Or you HF, that'll do you too. I didn't realize these suckers produced that, yikes.
@InTheGarden1960
1 month ago
Lithium batteries is what brought down mh370. I investigated that accident, just think how bad it was mixing those with salt water. Huge explosion.
@Spiethstar
1 month ago
Wow, that's pretty shocking.
Even with the knowledge, convenience is so hard to counteract that most people won't care about the risk till it's too late.
I'm a bit worried about my mom and her ebike that's in a storage room when she's not using it..
But there isn't a place to put besides there..
Now I know what my mom used to feel when I was testing my bulletproofness all these years..
@mobilecommunicationsnetwor5268
1 month ago
This video discusses the severe health risks associated with lithium-ion battery failures, focusing on a recent incident in Wyoming and medical research regarding lung injuries from toxic vapor inhalation.
Key takeaways:
The Wyoming Incident: A volunteer firefighter named Jack was hospitalized after a SMARTECH jump starter went into thermal runaway (0:00-0:50). Despite quickly moving the device outdoors, he later developed neurological symptoms, vision changes, confusion, and a stutter (0:54-1:13).
Toxic Vapor Hazards: When batteries enter thermal runaway, they release a highly toxic cloud containing carbon monoxide and other hazardous materials (1:16-1:26, 2:06-2:16, 3:15-3:28). The SMARTECH unit involved lacked a UL safety certification (1:39-1:53).
The Danger of Hydrogen Fluoride: A 2026 study from Dublin highlights how hydrogen fluoride gas, released during battery fires, binds with moisture in human airways to form hydrofluoric acid (4:18-4:31). This acid causes severe, often delayed, destruction of lung tissue, as documented in two e-bike battery fire cases (4:47-6:30).
Safety Recommendations: Because the damage from toxic inhalation may not appear immediately (6:31-6:49), the host stresses the importance of using SCBA (Self-Contained Breathing Apparatus) when dealing with any lithium-ion fire, even after the flames are extinguished (7:28-7:44).
@ronfarnsworth7074
1 month ago
What kind of Li batteries or electrolyte release hydrogen flouride?
@billsmith9249
1 month ago
Almost every cell phone uses lithium ion battery.. not sure if those would have the same effect.. what about power tools? I have dozens of Dewalt, Milwaukee, Kobalt, Ryobi batteries. ARe they emitting HF even if they're not on fire? Very scary stuff!
@franksmall1313
1 month ago
GOOD POINT...... LOT'S OF CHEM IN THINGS NOW DAYS. A LITTLE GOES A LONG WAYS. YOU ........ YES YOU . NOT GOING TO GO FAR WITHOUT YOUR LUNGS........... PERIOD.
@hohenzollern6025
1 month ago
Wait, so you are saying even firefighters have no clue how dangerous these are?
Heads should start rolling.
@POOKISTAN
1 month ago
So if you are in an apartment, should you just pull the fire alarm if/when there's a battery that does that so that people in other rooms are not exposed?
@mattcook3671
1 month ago
what is a basic level of filtration that would give even 1 minute of protection here? Is it just a airplane hood or can a AC filter mask get you out?
@mart0225
1 month ago
Are batteries with a CE label safe?
I have a jump starter - air compressor battery combo like in the video. No UL listing. Has a CE label. How should I dispose it?
@MarthaSchleuder
1 month ago
Why were lithium batteries allowed to be sold to consumers to begin with?
@grumpydrummer8960
1 month ago
There must be stricter Fire safety reviews of imported new power storage products being prepared for consumer markets. Strangely current systems. Alot of other Lithium-ion batteries produced for cameras and popular power tools are and have been the most safest with no dangers imposed. Even my own Hearing aids have lithium ion batteries,albeit tiny. Of course the manufacturing of these hazardous versions must come under scrutiny . How are we going to cope when tiny nuclear batteries enter the market, in the future?
@Evsmart-w8n
1 month ago
Trade one pollutant for another. Lithium batteries are highly toxic to people and our environment, a constant fire danger adding one more thing to an all ready polluted environment . EMF Radiation is another concern from these EVs
@ChRoNoS132
1 month ago (edited)
� who's betting her charger/jumpbox/compressor was bought on like Tik-Tox shop or Temu
@Rk_Dark94
1 month ago
Check out not sure what the load was maybe up your alley. Posted 4hrs ago incident from August 11 yesterday. Arkansas: Flatbed Truck Load Falls Off Truck & Catches Fire For HOURS (10x speed)
@StacheDTraining
1 month ago
I'm aware of the incident. It was a Megapack. Is there video out somewhere?
@Rk_Dark94
1 month ago
@StacheDTraining The only video I saw was from that traffic camera time lapse. Video on YouTube with that title from earlier comment
@christophersmith5303
1 month ago
The gases are a serious health threat but wait until we start to see the long-term impacts of the heavy metal nanoparticulates that are emitted in both venting and active fire in thermal runaway. Mutagenic, cytotoxic, carcinogens, genotoxic, and they can cause direct DNA strand breaks - they can pass through your skin, membranes, and of course easily enter your respiratory system and many of them are not readily shed by our bodies. It's going to be much worse than "PFAS"
@doesentmatter
1 month ago
I knew it was an hf injury hf acid can dissolve bone or rocks (silica) pulmonary tissue doesn't stand a chance
@emiliofimbrez1671
1 month ago
And these things are supposed to be safer for the environment?!
@Archangelm127
1 month ago
As if the cancer risk to firefighters from burning artificial materials of all sorts wasn't bad enough... �
@HankPA1
1 month ago
I watch a lot of firefighting videos. It seems that European firefighters are much faster to mask up than Americans.
@fountainvalley100
1 month ago
It's almost like you need to put the charging battery in a dry metal bucket. Next to it is a bucket of water. If it goes into runaway pour the water into the dry bucket and walk away.
Better would be for a company to make a bucket in a bucket. The customer fills the outer bucket with water. The water filled outer bucket would prevent the fire from spreading beyond the bucket.
@ernestyeagley512
1 month ago (edited)
Retired volunteer firefighter here. As long as these batteries are mfg. and available this unfortunate firefighter won't be the last to suffer from these unpredictable and dangerous power sources. Just a matter of time once again there will be a victim (or victims) and another house that burns to the ground. Sadly these lithium ion batteries won't go away, because they mean billions of dollars for the mfg. and for those that sell them (that power lazy kids' means of transportation such as bicycles and scooters). These wholesalers and retailers don't care about public safety. By the way I live near Amish country, and yet have I heard of an Amish child or young Amish adult die from overexertion pedaling a bike or pushing a scooter.
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@anthropicandroid4494
1 month ago
> Hydrogen Flouride
Say no more; if F- were any happier holding that frank negative charge, it would be Noble!
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@Wheresthabeef
1 month ago
This all sounds wonderful. Let's put lithium ion batteries in everything and ban every alternative.
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@Eduardo_Espinoza
1 month ago
EV people gas light people saying that they don't give you lung damage.
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@SalemikTUBE
1 month ago
How are these things legal? We seem to be just accepting that they are in every house and yet they want to ban my gas stove instead.
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@Eduardo_Espinoza
1 month ago
Instant asbestos lungs
So green like a leaf!
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@matthewsocal2540
1 month ago
RUN TO THE SOURCE! No, don't dawn that. Ignore your training. RUSH IN! Dumbfounding in 2026...no?
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@russellhltn1396
1 month ago
I'll bet this battery was bought on Amazon. I overheard the conversation of someone who lost a house to a battery fire. He tried to sue Amazon, but it turns out because Amazon doesn't have a "presence" (a retail store) in any state, they couldn't be sued. Trying to sue the maker (in China) was pointless.
If true, this is a major loophole in the consumer protection laws that needs to be closed. Consumers expect to be protected by consumer laws when they buy something from a US retailer.
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@shockingguy
1 month ago
Wow, this channel does provide some good information
The guy who runs it, Pat
Is an absolute slug at responding or engaging anyone on any of his platforms?
I have sent him private messages about specific questions I had from his videos and all I got was crickets
I'm not impressed with this guy at all. He's definitely full of himself unless he starts to say that he's not by showing that he's not.
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StacheD Training
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2 replies
@Eduardo_Espinoza
1 month ago
So green
so clean
0 emissions
Good for the environment.
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@LoFiNic2025
1 month ago
The whole world becomes TEMU...
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@billsElitetrucking349
1 month ago
I feel sorry for the firefighters that have to deal with these Deadly Lithium batteries.... batteries need to be Ban
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@avlisk
1 month ago
If you had 4 BattleBorn batteries sitting in your bedroom (for backup power during grid outages), would you get rid of them? What kind of battery would you replace them with? I'm thinking of taking the financial hit of $3600, and replacing them with AGM. Advice wanted, and thanks.
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@dave3657
1 month ago
Lithium ion batteries are the new asbestos. �⚰️
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@boerbiet237
1 month ago
Welke opties zijn er (veilig) als je ziet dat het fout gaat? �♂️
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@BryanTorok
1 month ago
I have a friend who tells me that he uses LiFePo4 (Lithium Iron Phosphate) batteries for radio communication backup systems. He claims when used with a proper battery management system (BMS) for charging and discharging they have no chance of catching on fire or going into thermal runaway. Is he correct?
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StacheD Training
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1 reply
@partidaportet27
1 month ago
Progress? Lithium Ion seems to be a technology we should consign to the garbage
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@romanseleven
1 month ago
Thank you for the sobering information. Due to the lack of reporting on the dangers of EVs and lithium ion batteries, it makes one wonder whether this is part of the depopulation agenda of the powers that be.
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@MapleMAGA1963
1 month ago
It's unfortunate that anyone that seriously tries to get rid of this danger will be attacked by all the ignorant people that think these batteries are saving the planet. Saving the planet one huge open pit mine at a time. That's just the cobalt you don't want to look into the water use to produce lithium.
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@davidhamtaro
1 month ago
What's a little sacrifice compared to saving the "environment" says the "How Dare You" green warriors .
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@barneyrubble9309
1 month ago (edited)
its all safe...trust me im a politician.
Weve put our safety in the hands of Chinese quality control...thats not gonna end well.
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@georgewills-ek1gg
1 month ago
What's with the poem? L0L.
l never trusted any of these dubious "Smartech" things, let alone anything with a lithium ion battery.
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@shortstoryteller-i5p
1 month ago
Hydrogen fluoride. It is one of the toxic gases produced by defective lithium ion batteries. �
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@Aprilsraven629
1 month ago
The law needs to change. Home owners, renters, and businesses need to know this, so a push for mandatory installation of carbon monoxide detectors in every property becomes law along side smoke alarms...
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@Cave5Critter
1 month ago
Lithium-Ion is way too general of an description. I bet is wasn't LiFePO4. Lithium-Ion is what you say if you hate all lithium batteries.
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@leonardkellum6984
1 month ago
Corporate amerika is selling them everywhere, I think they are a terrorists dream come true, and expect arson attacks involving them.
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@AntisocialRedNeckNerd
1 month ago
Lithium-ion batteries are in lots of products. They have become common. The potential danger is not talked about.
How do we know when to dispose of one of these batteries? How do we dispose of a lithium-ion battery correctly?
Ignorance is widespread on this topic. . .
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@matthewphair2469
1 month ago
'Lipo's" of any sort are lethal. I always charge ebike batteries outside. EV's total joke just one in the right place is going to kill hundreds not counting what they are doing to water aquifiers.
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@joescott6469
1 month ago
hear no eval .... speak no eval ....... Government cover up .....
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@solarlaura3355
1 month ago
We are surrounded by LI batteries everywhere we go. I've started carrying painters masks everywhere I go. I will load one for every passenger. If there is a cloud of smoke the masks go on. LI is so dangerous.
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@gerardwood4059
1 month ago
Lithium battery technologies are far more dangerous that the problem they are stupidly trying to solve, climet change.
Man made global warming is a disputed fact, natural global warming is a fact. Absolutely nothing man can do to stop the planet warming, all we can do is not speed it up, but thousands of toxic battery fires is making the air we breath poisonous to us. Time to ban them before the atmosphere is irrevocably made toxic.
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@HML-it7te
1 month ago
It's time we switch to sodium batteries.
Testing with steel rods rammed though them passed the tests.
They say these are much harder to combustion spontaneously.
I'm remember a firefighter in a southern Australian state having exposures resulting in loss of job, severe neurological damage FOR LIFE.
For christs sake, it's not worth it.
The battery industry needs to change over now, not in ten years.
Salt batteries can take much higher and cold-even extreme cold and function with extra wasted heating.
It's a no brainer.
It's also much more environmentally friendly and salt is so plentiful.
But we all know that "environmentally friendly" is just a term for politics.
I'm a retired dual trade (actually triple trade) Electrician Fitter/Mechanic, Linesman and Instrumentation Technician with a keen interest in solar and increasingly battery storage, but not for commercial reasons, only my own personal interest and increasing concerns that unintended consequences for Li battery storage on people's lives.
Home owners and well as Firefighters.
They shouldn't be sacrificed for something that can be changed for the better.
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@khriswildt5633
1 month ago
In other words made in China He's such a blowhard he loves her and himself talk it was made in China
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@georgevanheerden3563
1 month ago
Great pocast! Governments were quick on Covid! No reaction on EV battery fires! Statastical analysis- politicians only reacts positively to who is paying money into their political funds. We need to start using crypto. This will give a better audit trail on the flow of currency!
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@H-River_with_MR
1 month ago (edited)
Be careful with the dual smoke/CO detectors... The proper location is different for both fumes. Smoke goes Up, Carbon Dioxide goes down & will form Carbon Monoxide. Fire detector near the ceilings. CO detectors low on lowest level...
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@josh_gossett
1 month ago
H2OFl= awful if u look at it. Lol
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@josh_gossett
1 month ago
Hydrogen flouride...the thing they give us to drink and call water? Killing people? Nobody else thinks thats odd? I don't think adding oxygen fixes anything just saying
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@FrankFrankston-kj4sx
1 month ago
So who took names at the LA Fires. The largest single turnoff of EVs, Scooters and home batteries in the USA to date?
Answer? No one. This is a repeat. An example of "we learnt nothing!" From ASBESTOS and THALIDOMIDE.
Li-ion Batteries do more than burn.
20 years from now this generation of fire experts aren't going to be looked upon kindly.
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Thank you for studying the ecological impact! Please study the effects of PEIS and BESS impact on schools, noise and air pollution for neighborhoods, wells and well water, wetlands and sensitive receptors. I urge you to study the impact of battery fi...↓res as well, since they are so common at these facilities.
Thank you!↓
Thank you!↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Gaurav Vaidya and I live at 35020 SE Brinkley st. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Gaurav Vaidya
35020 SE Brinkley st↓
My name is Gaurav Vaidya and I live at 35020 SE Brinkley st. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Gaurav Vaidya
35020 SE Brinkley st↓
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To Whom it May Concern:
This letter is submitted on behalf of the City of Snoqualmie, in response to the Department of Ecology's request for public comment on the Scoping Document for Battery Energy Storage Systems (BESS) Programmatic Environmental ...↓Impact Statement, published in August, 2026 (Publication 26-06-017). I appreciate the opportunity to comment and bring the significant concerns of the broader Snoqualmie community to the Department of Ecology's attention. The comments are organized under the topics indicated below.
1. Proposal That Is the Subject of Proposed EIS.
The Scoping Document uses some terms not defined in Ecology's Model SEPA Rules, codified in ch. 197-11 WAC, and incorrectly uses others, to describe the proposal being analyzed. The Scoping Document is erroneous in this respect, and the errors must be corrected to ensure that the resulting environmental review is appropriately scoped and prepared.
For example, the Scoping Document refers to the proposed EIS as a "Programmatic EIS." "Programmatic" is not defined in the SEPA Rules; the correct terms are "nonproject EIS" and "project EIS." See WAC 197-11-774 (definition of "nonproject"); 197-11-784 (definition of "proposal"); 197-11-440- 443 (describing required contents of an EIS, an EIS on a nonproject proposal, and required contents of EIS prepared after nonproject EIS).
The Scoping Document also states that the EIS will not be a project-specific EIS. Scoping Document at 10 ("a PEIS is not a review of a specific project."); at 11 ("PEIS will consider potential significant impacts from general types of utility-scale lithium-ion BESS facilities; it is not site-specific or for a specific project."). The Scoping Document instead claims that it "is a
type of nonproject environmental review used for planning under the State Environmental Policy Act (SEPA)," and that it "is a planning document " Scoping Document at 9, 20. These
statements are incorrect.
The Scoping Document is not proposing that the EIS analyze a "Nonproject action," which is a term defined in the SEPA Rules. That term refers to "actions which are different or broader than a single site specific project, such as plans, policies, and programs (WAC 197-11-704)." WAC 197-11-774. The "plans, policies and programs" that constitute a "nonproject action" include adoption or amendment of legislation, ordinances, rules, or regulations," "adoption or amendment of comprehensive land use plans or zoning ordinances," and the "adoption of any policy, plan, or program that will govern the development of a series of connected actions." WAC 197-11-704(2)(b). The Scoping Document does not propose to analyze a "policy, plan or program." Had the Legislature conducted SEPA analysis on the Clean Energy Transformation Act, it might have prepared a nonproject EIS prior to adopting that proposed legislation Had PSE conducted SEPA environmental review of its Request for Proposals to construct a series of BESS facilities, the RFP might have have been considered a "nonproject action," and environmental review of it might have involved a nonporoject EIS. The Scoping Document does not pertain to "nonproject action," as that term is defined in Ecology's SEPA Rules.
Instead, the Scoping Document proposes to analyze a specific project, in the form of a generic, project-specific BESS facility, albeit one whose particular site and configuration are not known --or, at least, are not disclosed in the Scoping Document. Scoping Document at 20 ("PEIS will focus on stand-alone, utility-scale, lithium-ion BESS, the most likely to be proposed as projects over the next several years."). In other words, the Scoping Document is addressing construction and operation of a particular physical facility - a stand-alone BESS - that is a project-specific proposal.
The Scoping Document's erroneous reliance on the undefined term "Programmatic EIS," and its incorrect description of the "proposal" to be analyzed, are not academic errors, but has consequences for identification and analysis of alternatives (see below).
The Scoping Document also incorrectly refers to "tiering," another term not defined in the SEPA Rules. Scoping Document at 11 ("SEPA analyses for proposed BESS projects would tier to the PEIS. "Tiering" means when a broad nonproject evaluation is later used for a project."). The Scoping Document appears to be referring to "phased review," which "means the coverage of general matters in broader environmental documents, with subsequent narrower documents concentrating solely on the issues specific to the later analysis (WAC 197-11-060(5))." WAC 197-11-776. The Scoping Document appears to be attempting to come within WAC 197-11-060(5)(c)'s reference to the appropriate use of phased review to progress from broader,
nonproject environmental review to project-specific or site-specific review. But as noted above, there is no nonproject action for the Scoping Document or EIS to analyze.
It is important that the DEIS and FEIS correctly define the proposal that is the subject of their environmental review, so that the alternatives can be correctly identified and defined, and so that the environmental review includes the appropriate level of detail and impacts analysis. WAC 197-11-060(3) requires that "Agencies shall make certain that the proposal that is the subject of environmental review is properly defined."
2. Alternatives.
Because the Scoping Document incorrectly states that the EIS itself will be "a planning document," it concludes that an appropriate "No Action Alternative" would be the absence of the "PEIS" where "city, county, and state agencies would continue to conduct environmental review and permitting for BESS facilities under existing state and local laws on a project-by-project basis...." This is incorrect. The Scoping Document acknowledges that, even with preparation of the PEIS, "Proposed BESS facilities will need individual environmental review under SEPA using project- and site-specific information." The "No Action" alternative cannot be the same as alternatives following preparation of the PEIS. Instead, because the proposed PEIS is analyzing a project-specific action - construction and operation of a stand-alone, utility-scale BESS - the "No Action Alternative" must involve the operation of the energy grid without BESS. Simply put, where the proposed action is a "stand-alone, utility-scale, lithium-ion BESS," "no action" can only mean "no BESS," for purposes of environmental analysis and comparison of alternatives.
Per WAC 197-11-440(4), the EIS must describe and present the proposal and alternative courses of action. "Reasonable alternative" is defined in WAC 197-11-440(5) "to include actions that could feasibly attain or approximate a proposal's objectives, but at a lower environmental cost or decreased level of environmental degradation," including the "no action" alternative. See also WAC 197-11-440(6) (EIS for proposal for private project on a specific site must evaluate
"no action alternative plus other reasonable alternatives for achieving the proposal's objective ..
. ."). The EIS must "[d]evote sufficiently detailed analysis to each reasonable alternative to permit a comparative evaluation of the alternatives including the proposed action." Alternative sites should also be evaluated under WAC 197-11-44096) because at present, the Scoping Document does not indicate that any specific locations for a stand-alone BESS facility have been considered in existing Ecology planning documents. In selecting alternative sites for study, the EIS should consider sites with different distances (both horizontal and vertical) from residences and commercial uses.
WAC 197-11-440(5) permits an EIS to focus analysis on a "preferred alternative." The Scoping Document appears to indicate that lithium ion battery chemistry is a part of BESS preferred alternative. Therefore, any alternative discussed in the EIS should include one or more alternatives to lithium-ion battery chemistry, e.g., lithium iron phosphate (LFP) and/or sodium ion (SIB or Na-ion). Alternatives should also include different assumed site configurations and minimum battery container spacing. Aside from SEPA Rule requirements, the reason that alternative battery chemistry and BESS facility layouts need to be analyzed in the PEIS is that the different chemistries have differing energy densities, which in turn makes them differentially-susceptible to overheating, fire and explosion. Container contents, spacing and availability of automatic fire suppression systems also directly affect the likelihood of thermal propagation and thermal runaway. In order for the PEIS to adequately discuss impacts and make comparisons among alternatives, as required by WAC 197-11-440(5)(c)(iv), the PEIS must analyze one or more alternatives utilizing a battery chemistry other than lithium-ion, and utilize a different site plan and assumed container spacing that studied for the lithium ion preferred alternative.
Regarding appropriate sites, the Scoping Document at pages 20-11 states that the PEIS' scope "will be limited to the potential significant adverse environmental impacts in geographic areas that are suitable for utility-scale lithium-ion BESS," including "factors for likely development and proximity to existing infrastructure." The Scoping Document also invites input "on assumptions to identify the geographic scope of study used for the PEIS analysis." In this respect, the EIS should include one alternative site in an urban geographic area, with close proximity to electric utility substation or other power generation source, along with nearby residences, commercial businesses and other populated uses; it should also include an alternative site in an unpopulated or sparsely populated area with significant horizontal and vertical distance from residences, commercial businesses and other populated uses. Other considerations for geographic areas suitable for study should include geographic areas with greater and lesser wildfire risk, and areas with greater and lesser annual precipitation and history of drought.
3. Elements of the Environment.
The Scoping Document at page 21 generally identifies the appropriate elements of the environment for inclusion in the EIS. Because the PEIS is analyzing a "project action" and not a nonproject action, its analysis of significant, adverse environmental impacts is required to discuss "the principal features of the environment that would be affected, or created, by the alternatives including the proposal under consideration," including "significant impacts that will narrow the range or degree of beneficial uses of the environment or pose long term risks to human health or the environment, such as storage, handling, or disposal of toxic or hazardous material." WAC 197-11-440(6)(c). The analysis must also include "Significant impacts on both the natural environment and the built environment," including "impacts upon and the quality of
the physical surroundings, whether they are in wild, rural, or urban areas." WAC 197-11-440(6)(e). The EIS must include discussion of "the cost of and effects on public services, such as utilities, roads, fire, and police protection, that may result from a proposal," as well as "significant environmental impacts upon land and shoreline use, which includes housing, physical blight, and significant impacts of projected population on environmental resources." Id.
Given these requirements, and given that this EIS is not for a "nonproject action," it is critical that EIS analysis contain sufficient detail and analysis to address the significant adverse environmental impacts, particularly impacts arising from potential battery failures and fires. This is not a situation where the EIS may offer only generalized, non-specific discussion, on the grounds that it is for "nonproject action" where less detailed information is typically available. BESS facility impacts, including impacts from battery failures, are not "rare," as prior Ecology programmatic EISes have asserted, but regular and periodic. News reports of the most recent battery fire, involving a BESS attached to a metropolitan water district solar farm in La Verne, California, are attached. Given that a BESS facility is a "project action," and given the number of BESS failure events over the last five years, detailed information concerning impacts is readily available, and those impacts must be analyzed in detail in the EIS.
For example, the Scoping Document identifies "Water resources" as one of the elements for study. The "Water Resources" chapter needs to consider potential impacts to the following aspects:
• Analysis of potential water supply need (quantity, flow rate (gallons per minute) and duration) for BESS fire suppression needs, including:
i. water needed for cooling application to surrounding battery containers and structures, to avoid thermal runaway; and
ii. water for fire suppression on adjacent timber, vegetation and structures near or adjacent to a BESS site.
• Availability and sufficiency of water rights to meet water supply needs;
• Availability and sufficiency of water distribution and storage systems, including availability of piping, pump station(s), hydrants and storage tanks
• Legal availability of above systems;
• Water quality Impacts to water bodies (rivers, streams, wetlands) and aquatic life from runoff from fire suppression, including potential water contamination from battery fire constituents;
• Water quantity impacts to water bodies (rivers, streams, wetlands) and aquatic life from runoff from fire suppression.
Similarly, the elements analyzing impacts to air quality, and environmental health and safety, must include quantitative analysis of the following:
• Chemical constituents released during a battery fire, based on facility's battery chemistry (Li vs. LFP vs. SIB) ;
• Quantity of each chemical released, per hour of fire duration;
• Plume dispersion, including horizontal distance under modeled weather conditions; and
• Potential health impacts to residences and commercial businesses at modeled distances.
The foregoing examples are illustrative, but not exhaustive. Similar levels of detailed analysis are required for all of the elements of the environment noted in the Scoping Document, including without limitation noise and vibration, land use, and public services and utilities.
4. Mitigation Measures.
The EIS must include a description of mitigation measures meeting the requirements of WAC 197-11-440(6). Mitigation measures should include specific measures that state or local governments and communities may take to reduce the likelihood of significant adverse impacts from battery failures/ fires, including without limitation:
a. Specifying battery chemistry with lower risk of failure/ fire;
b. Limiting the number/ density of batteries per storage container;
c. Mandating increased minimum horizontal separation between battery containers to lower the risk of thermal runaway;
d. Mandating automated, remote: (i) fire detection; (ii) alarm and notification; and (iii) fire and explosion suppression mechanisms in battery storage containers;
e. Mandating compliance with updated versions of applicable uniform codes (including without limitation NFPA 855, UL 9540 and UL 9540A) in effect at the time of a BESS facility permit application, regardless of whether the uniform code has been adopted as part of the Washington State Building Code or Fire Code;
f. Mandating applicant payment of costs for local fire safety personnel training and response costs for BESS-related fire/ explosion incidents, with such training to occur prior to BESS facility energization and periodically throughout facility lifespan;
g. Requiring applicant-paid insurance in sufficient amounts to cover potential property damage, personal injuries, business interruption and evacuation/ relocation costs, for any BESS-related explosion, fire or other incident; and
h. Requiring preparation of and compliance with a commission/decommissioning plan that includes financial security, with periodic and increasing financial payments during facility operation, to ensure adequacy of financial security for fire/ emergency response costs, as well as for decommission at end of facility lifespan.
5. Expanded Scoping
Ecology should utilize expanded scoping, and hire experts and conduct appropriate field investigations to provide a basis for the detailed analysis described above. Ecology is authorized to do so under WAC 197-11-410(1)(c) and (4). Ecology should retain qualified experts in preparation of battery fire plume dispersion analysis, fire and emergency response plans, and firefighting response to BESS fire incidents, rather than relying upon electrical power industry data and reports, or electric car battery fire responses, as Ecology did in the 2025 PEIS prepared for industrial-scale solar facilities that include BESS. See, e.g., Environmental Health and Safety Technical Report, June 2025 at 50-52. Per WAC 197-11-410(f), Ecology should also coordinate with other entities with expertise, such as the National Fire Prevention Association (NFPA), the Washington Fire Chiefs Association, the National Association of Emergency and Fire Officials, and Underwriters Laboratories.
6. Conclusion.
I appreciate Ecology's involvement in this process, and willingness to take on the important task of analyzing environmental impacts from BESS facilities. I recognize and appreciate the significant allocation of resources this requires. I also urge Ecology to prepare the appropriately detailed, comprehensive project-level analysis, and not to hide the difficult impacts raised by these facilities under the guise of a "nonproject action," which an industrial-scale, stand-alone BESS facility is not.
Thank you in advance for your consideration of the above.
Sincerely,
James Mayhew, Mayor
CC: Snoqualmie City Council
↓
This letter is submitted on behalf of the City of Snoqualmie, in response to the Department of Ecology's request for public comment on the Scoping Document for Battery Energy Storage Systems (BESS) Programmatic Environmental ...↓Impact Statement, published in August, 2026 (Publication 26-06-017). I appreciate the opportunity to comment and bring the significant concerns of the broader Snoqualmie community to the Department of Ecology's attention. The comments are organized under the topics indicated below.
1. Proposal That Is the Subject of Proposed EIS.
The Scoping Document uses some terms not defined in Ecology's Model SEPA Rules, codified in ch. 197-11 WAC, and incorrectly uses others, to describe the proposal being analyzed. The Scoping Document is erroneous in this respect, and the errors must be corrected to ensure that the resulting environmental review is appropriately scoped and prepared.
For example, the Scoping Document refers to the proposed EIS as a "Programmatic EIS." "Programmatic" is not defined in the SEPA Rules; the correct terms are "nonproject EIS" and "project EIS." See WAC 197-11-774 (definition of "nonproject"); 197-11-784 (definition of "proposal"); 197-11-440- 443 (describing required contents of an EIS, an EIS on a nonproject proposal, and required contents of EIS prepared after nonproject EIS).
The Scoping Document also states that the EIS will not be a project-specific EIS. Scoping Document at 10 ("a PEIS is not a review of a specific project."); at 11 ("PEIS will consider potential significant impacts from general types of utility-scale lithium-ion BESS facilities; it is not site-specific or for a specific project."). The Scoping Document instead claims that it "is a
type of nonproject environmental review used for planning under the State Environmental Policy Act (SEPA)," and that it "is a planning document " Scoping Document at 9, 20. These
statements are incorrect.
The Scoping Document is not proposing that the EIS analyze a "Nonproject action," which is a term defined in the SEPA Rules. That term refers to "actions which are different or broader than a single site specific project, such as plans, policies, and programs (WAC 197-11-704)." WAC 197-11-774. The "plans, policies and programs" that constitute a "nonproject action" include adoption or amendment of legislation, ordinances, rules, or regulations," "adoption or amendment of comprehensive land use plans or zoning ordinances," and the "adoption of any policy, plan, or program that will govern the development of a series of connected actions." WAC 197-11-704(2)(b). The Scoping Document does not propose to analyze a "policy, plan or program." Had the Legislature conducted SEPA analysis on the Clean Energy Transformation Act, it might have prepared a nonproject EIS prior to adopting that proposed legislation Had PSE conducted SEPA environmental review of its Request for Proposals to construct a series of BESS facilities, the RFP might have have been considered a "nonproject action," and environmental review of it might have involved a nonporoject EIS. The Scoping Document does not pertain to "nonproject action," as that term is defined in Ecology's SEPA Rules.
Instead, the Scoping Document proposes to analyze a specific project, in the form of a generic, project-specific BESS facility, albeit one whose particular site and configuration are not known --or, at least, are not disclosed in the Scoping Document. Scoping Document at 20 ("PEIS will focus on stand-alone, utility-scale, lithium-ion BESS, the most likely to be proposed as projects over the next several years."). In other words, the Scoping Document is addressing construction and operation of a particular physical facility - a stand-alone BESS - that is a project-specific proposal.
The Scoping Document's erroneous reliance on the undefined term "Programmatic EIS," and its incorrect description of the "proposal" to be analyzed, are not academic errors, but has consequences for identification and analysis of alternatives (see below).
The Scoping Document also incorrectly refers to "tiering," another term not defined in the SEPA Rules. Scoping Document at 11 ("SEPA analyses for proposed BESS projects would tier to the PEIS. "Tiering" means when a broad nonproject evaluation is later used for a project."). The Scoping Document appears to be referring to "phased review," which "means the coverage of general matters in broader environmental documents, with subsequent narrower documents concentrating solely on the issues specific to the later analysis (WAC 197-11-060(5))." WAC 197-11-776. The Scoping Document appears to be attempting to come within WAC 197-11-060(5)(c)'s reference to the appropriate use of phased review to progress from broader,
nonproject environmental review to project-specific or site-specific review. But as noted above, there is no nonproject action for the Scoping Document or EIS to analyze.
It is important that the DEIS and FEIS correctly define the proposal that is the subject of their environmental review, so that the alternatives can be correctly identified and defined, and so that the environmental review includes the appropriate level of detail and impacts analysis. WAC 197-11-060(3) requires that "Agencies shall make certain that the proposal that is the subject of environmental review is properly defined."
2. Alternatives.
Because the Scoping Document incorrectly states that the EIS itself will be "a planning document," it concludes that an appropriate "No Action Alternative" would be the absence of the "PEIS" where "city, county, and state agencies would continue to conduct environmental review and permitting for BESS facilities under existing state and local laws on a project-by-project basis...." This is incorrect. The Scoping Document acknowledges that, even with preparation of the PEIS, "Proposed BESS facilities will need individual environmental review under SEPA using project- and site-specific information." The "No Action" alternative cannot be the same as alternatives following preparation of the PEIS. Instead, because the proposed PEIS is analyzing a project-specific action - construction and operation of a stand-alone, utility-scale BESS - the "No Action Alternative" must involve the operation of the energy grid without BESS. Simply put, where the proposed action is a "stand-alone, utility-scale, lithium-ion BESS," "no action" can only mean "no BESS," for purposes of environmental analysis and comparison of alternatives.
Per WAC 197-11-440(4), the EIS must describe and present the proposal and alternative courses of action. "Reasonable alternative" is defined in WAC 197-11-440(5) "to include actions that could feasibly attain or approximate a proposal's objectives, but at a lower environmental cost or decreased level of environmental degradation," including the "no action" alternative. See also WAC 197-11-440(6) (EIS for proposal for private project on a specific site must evaluate
"no action alternative plus other reasonable alternatives for achieving the proposal's objective ..
. ."). The EIS must "[d]evote sufficiently detailed analysis to each reasonable alternative to permit a comparative evaluation of the alternatives including the proposed action." Alternative sites should also be evaluated under WAC 197-11-44096) because at present, the Scoping Document does not indicate that any specific locations for a stand-alone BESS facility have been considered in existing Ecology planning documents. In selecting alternative sites for study, the EIS should consider sites with different distances (both horizontal and vertical) from residences and commercial uses.
WAC 197-11-440(5) permits an EIS to focus analysis on a "preferred alternative." The Scoping Document appears to indicate that lithium ion battery chemistry is a part of BESS preferred alternative. Therefore, any alternative discussed in the EIS should include one or more alternatives to lithium-ion battery chemistry, e.g., lithium iron phosphate (LFP) and/or sodium ion (SIB or Na-ion). Alternatives should also include different assumed site configurations and minimum battery container spacing. Aside from SEPA Rule requirements, the reason that alternative battery chemistry and BESS facility layouts need to be analyzed in the PEIS is that the different chemistries have differing energy densities, which in turn makes them differentially-susceptible to overheating, fire and explosion. Container contents, spacing and availability of automatic fire suppression systems also directly affect the likelihood of thermal propagation and thermal runaway. In order for the PEIS to adequately discuss impacts and make comparisons among alternatives, as required by WAC 197-11-440(5)(c)(iv), the PEIS must analyze one or more alternatives utilizing a battery chemistry other than lithium-ion, and utilize a different site plan and assumed container spacing that studied for the lithium ion preferred alternative.
Regarding appropriate sites, the Scoping Document at pages 20-11 states that the PEIS' scope "will be limited to the potential significant adverse environmental impacts in geographic areas that are suitable for utility-scale lithium-ion BESS," including "factors for likely development and proximity to existing infrastructure." The Scoping Document also invites input "on assumptions to identify the geographic scope of study used for the PEIS analysis." In this respect, the EIS should include one alternative site in an urban geographic area, with close proximity to electric utility substation or other power generation source, along with nearby residences, commercial businesses and other populated uses; it should also include an alternative site in an unpopulated or sparsely populated area with significant horizontal and vertical distance from residences, commercial businesses and other populated uses. Other considerations for geographic areas suitable for study should include geographic areas with greater and lesser wildfire risk, and areas with greater and lesser annual precipitation and history of drought.
3. Elements of the Environment.
The Scoping Document at page 21 generally identifies the appropriate elements of the environment for inclusion in the EIS. Because the PEIS is analyzing a "project action" and not a nonproject action, its analysis of significant, adverse environmental impacts is required to discuss "the principal features of the environment that would be affected, or created, by the alternatives including the proposal under consideration," including "significant impacts that will narrow the range or degree of beneficial uses of the environment or pose long term risks to human health or the environment, such as storage, handling, or disposal of toxic or hazardous material." WAC 197-11-440(6)(c). The analysis must also include "Significant impacts on both the natural environment and the built environment," including "impacts upon and the quality of
the physical surroundings, whether they are in wild, rural, or urban areas." WAC 197-11-440(6)(e). The EIS must include discussion of "the cost of and effects on public services, such as utilities, roads, fire, and police protection, that may result from a proposal," as well as "significant environmental impacts upon land and shoreline use, which includes housing, physical blight, and significant impacts of projected population on environmental resources." Id.
Given these requirements, and given that this EIS is not for a "nonproject action," it is critical that EIS analysis contain sufficient detail and analysis to address the significant adverse environmental impacts, particularly impacts arising from potential battery failures and fires. This is not a situation where the EIS may offer only generalized, non-specific discussion, on the grounds that it is for "nonproject action" where less detailed information is typically available. BESS facility impacts, including impacts from battery failures, are not "rare," as prior Ecology programmatic EISes have asserted, but regular and periodic. News reports of the most recent battery fire, involving a BESS attached to a metropolitan water district solar farm in La Verne, California, are attached. Given that a BESS facility is a "project action," and given the number of BESS failure events over the last five years, detailed information concerning impacts is readily available, and those impacts must be analyzed in detail in the EIS.
For example, the Scoping Document identifies "Water resources" as one of the elements for study. The "Water Resources" chapter needs to consider potential impacts to the following aspects:
• Analysis of potential water supply need (quantity, flow rate (gallons per minute) and duration) for BESS fire suppression needs, including:
i. water needed for cooling application to surrounding battery containers and structures, to avoid thermal runaway; and
ii. water for fire suppression on adjacent timber, vegetation and structures near or adjacent to a BESS site.
• Availability and sufficiency of water rights to meet water supply needs;
• Availability and sufficiency of water distribution and storage systems, including availability of piping, pump station(s), hydrants and storage tanks
• Legal availability of above systems;
• Water quality Impacts to water bodies (rivers, streams, wetlands) and aquatic life from runoff from fire suppression, including potential water contamination from battery fire constituents;
• Water quantity impacts to water bodies (rivers, streams, wetlands) and aquatic life from runoff from fire suppression.
Similarly, the elements analyzing impacts to air quality, and environmental health and safety, must include quantitative analysis of the following:
• Chemical constituents released during a battery fire, based on facility's battery chemistry (Li vs. LFP vs. SIB) ;
• Quantity of each chemical released, per hour of fire duration;
• Plume dispersion, including horizontal distance under modeled weather conditions; and
• Potential health impacts to residences and commercial businesses at modeled distances.
The foregoing examples are illustrative, but not exhaustive. Similar levels of detailed analysis are required for all of the elements of the environment noted in the Scoping Document, including without limitation noise and vibration, land use, and public services and utilities.
4. Mitigation Measures.
The EIS must include a description of mitigation measures meeting the requirements of WAC 197-11-440(6). Mitigation measures should include specific measures that state or local governments and communities may take to reduce the likelihood of significant adverse impacts from battery failures/ fires, including without limitation:
a. Specifying battery chemistry with lower risk of failure/ fire;
b. Limiting the number/ density of batteries per storage container;
c. Mandating increased minimum horizontal separation between battery containers to lower the risk of thermal runaway;
d. Mandating automated, remote: (i) fire detection; (ii) alarm and notification; and (iii) fire and explosion suppression mechanisms in battery storage containers;
e. Mandating compliance with updated versions of applicable uniform codes (including without limitation NFPA 855, UL 9540 and UL 9540A) in effect at the time of a BESS facility permit application, regardless of whether the uniform code has been adopted as part of the Washington State Building Code or Fire Code;
f. Mandating applicant payment of costs for local fire safety personnel training and response costs for BESS-related fire/ explosion incidents, with such training to occur prior to BESS facility energization and periodically throughout facility lifespan;
g. Requiring applicant-paid insurance in sufficient amounts to cover potential property damage, personal injuries, business interruption and evacuation/ relocation costs, for any BESS-related explosion, fire or other incident; and
h. Requiring preparation of and compliance with a commission/decommissioning plan that includes financial security, with periodic and increasing financial payments during facility operation, to ensure adequacy of financial security for fire/ emergency response costs, as well as for decommission at end of facility lifespan.
5. Expanded Scoping
Ecology should utilize expanded scoping, and hire experts and conduct appropriate field investigations to provide a basis for the detailed analysis described above. Ecology is authorized to do so under WAC 197-11-410(1)(c) and (4). Ecology should retain qualified experts in preparation of battery fire plume dispersion analysis, fire and emergency response plans, and firefighting response to BESS fire incidents, rather than relying upon electrical power industry data and reports, or electric car battery fire responses, as Ecology did in the 2025 PEIS prepared for industrial-scale solar facilities that include BESS. See, e.g., Environmental Health and Safety Technical Report, June 2025 at 50-52. Per WAC 197-11-410(f), Ecology should also coordinate with other entities with expertise, such as the National Fire Prevention Association (NFPA), the Washington Fire Chiefs Association, the National Association of Emergency and Fire Officials, and Underwriters Laboratories.
6. Conclusion.
I appreciate Ecology's involvement in this process, and willingness to take on the important task of analyzing environmental impacts from BESS facilities. I recognize and appreciate the significant allocation of resources this requires. I also urge Ecology to prepare the appropriately detailed, comprehensive project-level analysis, and not to hide the difficult impacts raised by these facilities under the guise of a "nonproject action," which an industrial-scale, stand-alone BESS facility is not.
Thank you in advance for your consideration of the above.
Sincerely,
James Mayhew, Mayor
CC: Snoqualmie City Council
↓
Attachments:
I have watched with horror as a battery storage facility near my hometown has disrupted life and endangered citizens, wildlife, and agriculture for months and months. As a retired public safety dispatcher, I am far too familiar with the danger of ha...↓ving facilities that cause problems than cannot be contained too close to residential areas. Literally there is nothing to do but wait if these facilities have a fire- which happened. It was in trying to remove the undamaged batteries left in the building that the fire began again- causing 4 public schools to shelter in place and residents to again start googling 'danger from battery fires.' We don't yet have the knowledge technology to mitigate the dangers. Putting these close to humans is immoral and dangerous↓
No attachments
We cannot let these facilities into our residential areas. There must be restrictions around schools, homes, and hospitals regardless of any scope! The volume of emergencies and amount of fires, evacuations, harm to our environment, waterways, air, a...↓nimals, and more is proof enough that these do not belong around wildlife, waterways, or people! Keep them out and limited to industrial areas if they must exist at all.↓
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Noise Pollution, Public Health, and Potential Disproportionate Impacts on Persons with Disabilities and Sensory Sensitivities
To the Department of Ecology, Clean Energy Coordination:
I respectfully submit this additional scoping comment concerning ...↓the Programmatic Environmental Impact Statement ("PEIS") for stand-alone, utility-scale battery energy storage system ("BESS") facilities in Washington State.
The Washington State Department of Ecology Battery Storage PEIS states that Ecology is studying potential negative impacts of stand-alone, utility-scale BESS facilities, including measures to avoid, reduce, or mitigate those impacts. Ecology also acknowledges that previous battery studies identified higher noise levels among potential impacts.
For these reasons, I respectfully request that the PEIS specifically evaluate operational noise pollution as a potential public-health and accessibility concern, including whether residents with disabilities, neurodevelopmental conditions, sensory-processing differences, sleep disorders, and other conditions associated with sound sensitivity may experience disproportionate functional effects when utility-scale BESS facilities are located near residences.
This issue warrants specific consideration rather than being addressed solely through a generalized community-noise analysis.
1. Environmental Noise Should Be Evaluated as a Public-Health Issue
Noise should not be assessed solely as an issue of inconvenience, nuisance, or compliance with an average exterior decibel limit.
The World Health Organization Guidance on Environmental Noise identifies excessive environmental noise as capable of causing annoyance and reports evidence concerning increased risks of ischemic heart disease and hypertension, sleep disturbance, hearing impairment, tinnitus, and cognitive impairment, with increasing evidence concerning additional health outcomes including mental-health effects.
WHO's environmental-noise materials address environmental sources including transportation and industry rather than being limited to occupational noise.
I recognize that the WHO evidence principally concerns environmental noise generally and does not establish that BESS facilities specifically cause these health effects. Nevertheless, this evidence demonstrates why persistent environmental noise near residences warrants careful public-health evaluation when assessing a new industrial noise source.
Because the PEIS is intended to identify potential adverse impacts and measures to avoid, reduce, or mitigate them, I request that residential noise exposure, including potential impacts on noise-sensitive populations, be expressly included within the scope of the human-health and noise analysis.
2. Persons With Disabilities and Sensory-Processing Differences Require Specific Consideration
An environmental analysis based solely upon the response of an "average" resident may fail to identify impacts experienced by individuals whose disabilities or health conditions affect their response to environmental stimuli.
The PEIS should investigate whether potentially noise-sensitive populations may include individuals with conditions such as:
attention-deficit/hyperactivity disorder ("ADHD");
sensory-processing differences;
autism spectrum conditions;
hyperacusis or tinnitus;
migraines associated with sound sensitivity;
post-traumatic stress disorder;
anxiety or panic disorders;
traumatic brain injury;
cognitive disabilities; and
insomnia and other sleep disorders.
Scientific evidence supporting examination of sensory-processing differences in certain populations.
For example, a 2025 systematic review and meta-analysis addressing ADHD and sensory processing evaluated 30 studies encompassing 5,374 participants. The researchers reported significantly greater sensory atypicalities among individuals with ADHD than control populations across several domains, including sensory sensitivity and sensory avoiding. The researchers also reported substantial heterogeneity among the studies.
This scientific evidence supports the more limited and relevant conclusion that sensory response is not uniform across the population and that an environmental review should investigate whether residents with heightened sensory sensitivity may experience persistent environmental noise differently from the general population.
3. The Residential Environment Deserves Particular Protection in the Noise Analysis
For individuals with sensory sensitivities or other noise-sensitive conditions, the home may be one of the most important environments in which external stimulation can be controlled.
Consequently, evaluation of a BESS facility near residences should not end with determining whether sound levels approach thresholds associated with hearing damage.
The PEIS should investigate whether chronic, recurring, intermittent, or tonal operational noise could interfere with:
sleep and nighttime recovery;
concentration;
learning and homework;
working from home;
communication;
ordinary indoor activities;
use of yards and other outdoor residential areas; and
the ability of noise-sensitive residents to obtain relief from unwanted environmental stimulation within their homes.
WHO materials identify sleep disturbance, annoyance, and cognitive impairment among the adverse outcomes associated with excessive environmental noise.
This general environmental-noise evidence provides a scientifically legitimate basis for asking Ecology to evaluate the issue before large industrial battery facilities are situated near residential communities.
4. The Analysis Should Not Rely Exclusively on a Single Average dBA Measurement
I respectfully request that Ecology evaluate whether reliance upon a single A-weighted average decibel measurement adequately characterizes the potential effect of BESS operations on nearby residences and noise-sensitive populations.
The PEIS should evaluate whether project-level acoustic assessments should consider additional characteristics including:
daytime and nighttime sound separately;
existing background or ambient sound conditions;
continuous versus intermittent sound;
tonal characteristics;
low-frequency sound components;
equipment cycling;
maximum sound events;
simultaneous operation of multiple pieces of equipment;
cumulative sound from the BESS together with relevant existing sources;
sound levels at nearby residences and other sensitive receptors;
potential indoor residential and bedroom exposure; and
reasonably foreseeable operating conditions associated with elevated noise generation.
This is particularly important in residential areas where the pre-existing nighttime acoustic environment may be substantially quieter than an industrial environment.
The question should therefore not merely be whether a facility satisfies an applicable numerical noise standard. The PEIS should also evaluate whether the methodology used to characterize noise adequately represents the actual residential exposure that nearby communities may experience.
5. Nighttime Noise and Sleep Deserve Separate Evaluation
Nighttime exposure should receive particular attention.
WHO identifies sleep disturbance as an adverse effect associated with excessive environmental noise and has incorporated sleep disturbance and annoyance into its work assessing environmental-noise health burdens.
For individuals who already experience neurological, sensory, psychological, or sleep-related vulnerabilities, disruption of the residential nighttime acoustic environment warrants explicit investigation.
I therefore request that Ecology evaluate whether project-level noise studies should assess BESS sound reaching nearby residences during the quietest nighttime conditions, including potential indoor bedroom exposure where technically appropriate.
Nighttime impacts should not be obscured by reliance solely upon a longer-term average that combines louder daytime ambient conditions with quieter nighttime conditions.
6. The PEIS Should Establish a Protective Noise-Assessment Framework
Because Ecology states that this study will lay the foundation for future project-level environmental reviews, the methodology developed at the programmatic stage is particularly important.
I respectfully request that Ecology evaluate whether future project-level BESS acoustic assessments should include:
preconstruction baseline ambient-noise measurements;
separate daytime and nighttime analysis;
evaluation at the nearest residences and sensitive receptors;
frequency-specific analysis where appropriate;
assessment of tonal and low-frequency characteristics;
intermittent and cycling noise;
simultaneous operation of relevant equipment;
reasonably foreseeable higher-noise operating conditions;
appropriate consideration of weather, topography, and sound propagation;
cumulative noise from relevant sources;
post-construction verification measurements; and
enforceable corrective mitigation where predicted acoustic performance is not achieved.
Establishing an appropriate methodology at the PEIS level would allow subsequent environmental reviews to evaluate residential noise impacts more consistently and transparently.
7. Disability and Accessibility Impacts Should Be Expressly Considered
Ecology's BESS scoping materials expressly state the Department's commitment to providing people with disabilities access to information and services and reference the Americans with Disabilities Act, Sections 504 and 508 of the Rehabilitation Act, and Washington State Policy #188.
I do not contend through this comment that those provisions independently require Ecology to reach a particular substantive conclusion concerning BESS noise.
Rather, consistent with Ecology's stated commitment to accessibility, I respectfully ask the Department to consider disability and sensory vulnerability as part of its evaluation of potential human-health and residential-noise impacts.
The PEIS should specifically examine whether siting a continuously or intermittently operating industrial facility near residences could create disproportionate functional impacts for individuals whose disabilities or health conditions make their residential acoustic environment particularly important.
The analysis should recognize individual variability and should not assume that everyone sharing a particular diagnosis will respond to sound in the same manner.
8. Mitigation Should Focus on the Facility Rather Than Shifting the Burden to Residents
Where potentially significant residential noise impacts are identified, I request that the PEIS evaluate avoidance and mitigation measures during planning and siting rather than waiting until residents experience adverse effects after facility construction.
Potential measures for evaluation should include, where technically appropriate:
adequate separation between major noise-producing equipment and residences;
facility layout and equipment orientation;
selection of quieter equipment;
acoustic enclosures or barriers;
nighttime operational controls where warranted;
post-construction noise monitoring;
accessible complaint procedures; and
enforceable corrective measures where actual operating noise exceeds modeled or permitted conditions.
Most importantly, mitigation should focus first on reducing noise at its source or through facility design and siting, rather than transferring responsibility to nearby residents.
Residents, particularly those with disabilities or sensory sensitivities, should not be expected to rely upon permanently closed windows, continuous personal hearing protection, relocation of bedrooms, or abandonment of normal use of outdoor areas as substitutes for appropriate facility siting and effective noise control.
9. Requested PEIS Finding and Scope of Analysis
I respectfully request that Ecology recognize the following principle within the PEIS:
Operational noise from utility-scale BESS facilities located near residences warrants evaluation as a potential public-health and accessibility concern, including consideration of nighttime exposure, existing ambient conditions, tonality, low-frequency characteristics, intermittency, cumulative noise, indoor residential exposure, and potentially noise-sensitive populations.
I further request that the PEIS establish an evidence-based technical framework for evaluating these factors during subsequent project-level environmental review and identify measures capable of avoiding, reducing, or mitigating significant residential noise impacts.
Ecology states that the BESS study is examining potential negative impacts of stand-alone utility-scale battery storage and methods for avoiding, reducing, or mitigating those impacts, and that the study will provide the foundation for later project-level environmental reviews.
For precisely this reason, noise impacts on persons with disabilities and other noise-sensitive residents should be examined at the programmatic stage rather than first being addressed after a specific facility has been designed, permitted, constructed, or placed into operation.
A scientifically responsible assessment does not require Ecology to presume that BESS noise will cause a particular disease or disability. It requires the Department to recognize that environmental-noise exposure can have health and functional consequences, that sensitivity to environmental sound varies across the population, and that potentially vulnerable populations should not be overlooked when evaluating industrial facilities proposed near residential communities.
Thank you for considering this comment and for ensuring that Washington's evaluation of utility-scale battery energy storage systems considers both the general population and residents who may experience heightened vulnerability to changes in their residential acoustic environment.
Respectfully submitted,
Henrika Stich
36702 SE Gravenstein Ct.
Snoqualmie, Washington
Supporting authorities
Washington State Department of Ecology, Scoping Document for Battery Energy Storage Systems Programmatic Environmental Impact Statement, Publication 26-06-017. Ecology's scoping materials describe the BESS PEIS and its accessibility commitment.
Washington State Department of Ecology, Battery Storage. Ecology states that it is studying potential negative impacts from stand-alone utility-scale BESS facilities and identifies higher noise levels among impacts found in its previous battery studies.
World Health Organization, Guidance on Environmental Noise. WHO identifies a range of health effects associated with excessive environmental noise, including annoyance, sleep disturbance and cognitive impairment, among others.
World Health Organization, Environmental Noise. WHO discusses environmental noise exposure and associated health considerations.
Sensory Processing in Individuals With Attention-Deficit/Hyperactivity Disorder Compared With Control Populations: A Systematic Review and Meta-analysis. The 2025 analysis reports greater sensory-processing atypicalities among people with ADHD across multiple domains while also reporting heterogeneity in the available studies.↓
To the Department of Ecology, Clean Energy Coordination:
I respectfully submit this additional scoping comment concerning ...↓the Programmatic Environmental Impact Statement ("PEIS") for stand-alone, utility-scale battery energy storage system ("BESS") facilities in Washington State.
The Washington State Department of Ecology Battery Storage PEIS states that Ecology is studying potential negative impacts of stand-alone, utility-scale BESS facilities, including measures to avoid, reduce, or mitigate those impacts. Ecology also acknowledges that previous battery studies identified higher noise levels among potential impacts.
For these reasons, I respectfully request that the PEIS specifically evaluate operational noise pollution as a potential public-health and accessibility concern, including whether residents with disabilities, neurodevelopmental conditions, sensory-processing differences, sleep disorders, and other conditions associated with sound sensitivity may experience disproportionate functional effects when utility-scale BESS facilities are located near residences.
This issue warrants specific consideration rather than being addressed solely through a generalized community-noise analysis.
1. Environmental Noise Should Be Evaluated as a Public-Health Issue
Noise should not be assessed solely as an issue of inconvenience, nuisance, or compliance with an average exterior decibel limit.
The World Health Organization Guidance on Environmental Noise identifies excessive environmental noise as capable of causing annoyance and reports evidence concerning increased risks of ischemic heart disease and hypertension, sleep disturbance, hearing impairment, tinnitus, and cognitive impairment, with increasing evidence concerning additional health outcomes including mental-health effects.
WHO's environmental-noise materials address environmental sources including transportation and industry rather than being limited to occupational noise.
I recognize that the WHO evidence principally concerns environmental noise generally and does not establish that BESS facilities specifically cause these health effects. Nevertheless, this evidence demonstrates why persistent environmental noise near residences warrants careful public-health evaluation when assessing a new industrial noise source.
Because the PEIS is intended to identify potential adverse impacts and measures to avoid, reduce, or mitigate them, I request that residential noise exposure, including potential impacts on noise-sensitive populations, be expressly included within the scope of the human-health and noise analysis.
2. Persons With Disabilities and Sensory-Processing Differences Require Specific Consideration
An environmental analysis based solely upon the response of an "average" resident may fail to identify impacts experienced by individuals whose disabilities or health conditions affect their response to environmental stimuli.
The PEIS should investigate whether potentially noise-sensitive populations may include individuals with conditions such as:
attention-deficit/hyperactivity disorder ("ADHD");
sensory-processing differences;
autism spectrum conditions;
hyperacusis or tinnitus;
migraines associated with sound sensitivity;
post-traumatic stress disorder;
anxiety or panic disorders;
traumatic brain injury;
cognitive disabilities; and
insomnia and other sleep disorders.
Scientific evidence supporting examination of sensory-processing differences in certain populations.
For example, a 2025 systematic review and meta-analysis addressing ADHD and sensory processing evaluated 30 studies encompassing 5,374 participants. The researchers reported significantly greater sensory atypicalities among individuals with ADHD than control populations across several domains, including sensory sensitivity and sensory avoiding. The researchers also reported substantial heterogeneity among the studies.
This scientific evidence supports the more limited and relevant conclusion that sensory response is not uniform across the population and that an environmental review should investigate whether residents with heightened sensory sensitivity may experience persistent environmental noise differently from the general population.
3. The Residential Environment Deserves Particular Protection in the Noise Analysis
For individuals with sensory sensitivities or other noise-sensitive conditions, the home may be one of the most important environments in which external stimulation can be controlled.
Consequently, evaluation of a BESS facility near residences should not end with determining whether sound levels approach thresholds associated with hearing damage.
The PEIS should investigate whether chronic, recurring, intermittent, or tonal operational noise could interfere with:
sleep and nighttime recovery;
concentration;
learning and homework;
working from home;
communication;
ordinary indoor activities;
use of yards and other outdoor residential areas; and
the ability of noise-sensitive residents to obtain relief from unwanted environmental stimulation within their homes.
WHO materials identify sleep disturbance, annoyance, and cognitive impairment among the adverse outcomes associated with excessive environmental noise.
This general environmental-noise evidence provides a scientifically legitimate basis for asking Ecology to evaluate the issue before large industrial battery facilities are situated near residential communities.
4. The Analysis Should Not Rely Exclusively on a Single Average dBA Measurement
I respectfully request that Ecology evaluate whether reliance upon a single A-weighted average decibel measurement adequately characterizes the potential effect of BESS operations on nearby residences and noise-sensitive populations.
The PEIS should evaluate whether project-level acoustic assessments should consider additional characteristics including:
daytime and nighttime sound separately;
existing background or ambient sound conditions;
continuous versus intermittent sound;
tonal characteristics;
low-frequency sound components;
equipment cycling;
maximum sound events;
simultaneous operation of multiple pieces of equipment;
cumulative sound from the BESS together with relevant existing sources;
sound levels at nearby residences and other sensitive receptors;
potential indoor residential and bedroom exposure; and
reasonably foreseeable operating conditions associated with elevated noise generation.
This is particularly important in residential areas where the pre-existing nighttime acoustic environment may be substantially quieter than an industrial environment.
The question should therefore not merely be whether a facility satisfies an applicable numerical noise standard. The PEIS should also evaluate whether the methodology used to characterize noise adequately represents the actual residential exposure that nearby communities may experience.
5. Nighttime Noise and Sleep Deserve Separate Evaluation
Nighttime exposure should receive particular attention.
WHO identifies sleep disturbance as an adverse effect associated with excessive environmental noise and has incorporated sleep disturbance and annoyance into its work assessing environmental-noise health burdens.
For individuals who already experience neurological, sensory, psychological, or sleep-related vulnerabilities, disruption of the residential nighttime acoustic environment warrants explicit investigation.
I therefore request that Ecology evaluate whether project-level noise studies should assess BESS sound reaching nearby residences during the quietest nighttime conditions, including potential indoor bedroom exposure where technically appropriate.
Nighttime impacts should not be obscured by reliance solely upon a longer-term average that combines louder daytime ambient conditions with quieter nighttime conditions.
6. The PEIS Should Establish a Protective Noise-Assessment Framework
Because Ecology states that this study will lay the foundation for future project-level environmental reviews, the methodology developed at the programmatic stage is particularly important.
I respectfully request that Ecology evaluate whether future project-level BESS acoustic assessments should include:
preconstruction baseline ambient-noise measurements;
separate daytime and nighttime analysis;
evaluation at the nearest residences and sensitive receptors;
frequency-specific analysis where appropriate;
assessment of tonal and low-frequency characteristics;
intermittent and cycling noise;
simultaneous operation of relevant equipment;
reasonably foreseeable higher-noise operating conditions;
appropriate consideration of weather, topography, and sound propagation;
cumulative noise from relevant sources;
post-construction verification measurements; and
enforceable corrective mitigation where predicted acoustic performance is not achieved.
Establishing an appropriate methodology at the PEIS level would allow subsequent environmental reviews to evaluate residential noise impacts more consistently and transparently.
7. Disability and Accessibility Impacts Should Be Expressly Considered
Ecology's BESS scoping materials expressly state the Department's commitment to providing people with disabilities access to information and services and reference the Americans with Disabilities Act, Sections 504 and 508 of the Rehabilitation Act, and Washington State Policy #188.
I do not contend through this comment that those provisions independently require Ecology to reach a particular substantive conclusion concerning BESS noise.
Rather, consistent with Ecology's stated commitment to accessibility, I respectfully ask the Department to consider disability and sensory vulnerability as part of its evaluation of potential human-health and residential-noise impacts.
The PEIS should specifically examine whether siting a continuously or intermittently operating industrial facility near residences could create disproportionate functional impacts for individuals whose disabilities or health conditions make their residential acoustic environment particularly important.
The analysis should recognize individual variability and should not assume that everyone sharing a particular diagnosis will respond to sound in the same manner.
8. Mitigation Should Focus on the Facility Rather Than Shifting the Burden to Residents
Where potentially significant residential noise impacts are identified, I request that the PEIS evaluate avoidance and mitigation measures during planning and siting rather than waiting until residents experience adverse effects after facility construction.
Potential measures for evaluation should include, where technically appropriate:
adequate separation between major noise-producing equipment and residences;
facility layout and equipment orientation;
selection of quieter equipment;
acoustic enclosures or barriers;
nighttime operational controls where warranted;
post-construction noise monitoring;
accessible complaint procedures; and
enforceable corrective measures where actual operating noise exceeds modeled or permitted conditions.
Most importantly, mitigation should focus first on reducing noise at its source or through facility design and siting, rather than transferring responsibility to nearby residents.
Residents, particularly those with disabilities or sensory sensitivities, should not be expected to rely upon permanently closed windows, continuous personal hearing protection, relocation of bedrooms, or abandonment of normal use of outdoor areas as substitutes for appropriate facility siting and effective noise control.
9. Requested PEIS Finding and Scope of Analysis
I respectfully request that Ecology recognize the following principle within the PEIS:
Operational noise from utility-scale BESS facilities located near residences warrants evaluation as a potential public-health and accessibility concern, including consideration of nighttime exposure, existing ambient conditions, tonality, low-frequency characteristics, intermittency, cumulative noise, indoor residential exposure, and potentially noise-sensitive populations.
I further request that the PEIS establish an evidence-based technical framework for evaluating these factors during subsequent project-level environmental review and identify measures capable of avoiding, reducing, or mitigating significant residential noise impacts.
Ecology states that the BESS study is examining potential negative impacts of stand-alone utility-scale battery storage and methods for avoiding, reducing, or mitigating those impacts, and that the study will provide the foundation for later project-level environmental reviews.
For precisely this reason, noise impacts on persons with disabilities and other noise-sensitive residents should be examined at the programmatic stage rather than first being addressed after a specific facility has been designed, permitted, constructed, or placed into operation.
A scientifically responsible assessment does not require Ecology to presume that BESS noise will cause a particular disease or disability. It requires the Department to recognize that environmental-noise exposure can have health and functional consequences, that sensitivity to environmental sound varies across the population, and that potentially vulnerable populations should not be overlooked when evaluating industrial facilities proposed near residential communities.
Thank you for considering this comment and for ensuring that Washington's evaluation of utility-scale battery energy storage systems considers both the general population and residents who may experience heightened vulnerability to changes in their residential acoustic environment.
Respectfully submitted,
Henrika Stich
36702 SE Gravenstein Ct.
Snoqualmie, Washington
Supporting authorities
Washington State Department of Ecology, Scoping Document for Battery Energy Storage Systems Programmatic Environmental Impact Statement, Publication 26-06-017. Ecology's scoping materials describe the BESS PEIS and its accessibility commitment.
Washington State Department of Ecology, Battery Storage. Ecology states that it is studying potential negative impacts from stand-alone utility-scale BESS facilities and identifies higher noise levels among impacts found in its previous battery studies.
World Health Organization, Guidance on Environmental Noise. WHO identifies a range of health effects associated with excessive environmental noise, including annoyance, sleep disturbance and cognitive impairment, among others.
World Health Organization, Environmental Noise. WHO discusses environmental noise exposure and associated health considerations.
Sensory Processing in Individuals With Attention-Deficit/Hyperactivity Disorder Compared With Control Populations: A Systematic Review and Meta-analysis. The 2025 analysis reports greater sensory-processing atypicalities among people with ADHD across multiple domains while also reporting heterogeneity in the available studies.↓
To the Department of Ecology, Clean Energy Coordination:
My name is Megan Stobie and I live at 34914 SE Brinkley St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." We live in an area with only a couple of roads in and out and also downstream from this location is Snoqualmie Falls, Snoqualmie River, an Elk herd and flood zone. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My household depends on Railroad Ave / SR 202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Megan Stobie
34914 SE Brinkley St↓
My name is Megan Stobie and I live at 34914 SE Brinkley St. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." We live in an area with only a couple of roads in and out and also downstream from this location is Snoqualmie Falls, Snoqualmie River, an Elk herd and flood zone. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My household depends on Railroad Ave / SR 202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Megan Stobie
34914 SE Brinkley St↓
No attachments
SVRE Comments are in attached file, "SVRE BESS PEIS Scoping Letter to Ecology.pdf."
Attachments:
To the Department of Ecology, Clean Energy Coordination:
OneEnergy Development, LLC ("OneEnergy Renewables") is a solar development company headquartered in Seattle, Washington. We have developed over 120 MW of solar projects within the state and a...↓re hoping to build out a local storage portfolio.
We appreciate the opportunity to comment on the scoping document and support Ecology's efforts to develop a programmatic environmental analysis of stand-alone, utility-scale battery energy storage systems (BESS).
Section 3.1.2 (page 16) of the draft scoping document sorts BESS into two classes by power capacity: residential/commercial facilities below 1 MW, and utility-scale facilities of 1 MW or more. The document proposes focusing the PEIS on the utility-scale class, and Ecology states that it will determine the specific type of facility to be evaluated after considering scoping input.
We recommend Ecology disaggregate and study large-scale facilities (over 50MW) and distributed facilities (1-50MW) independently. The environmental impacts associated with these can vary greatly, and ascribing the attributes of large-scale facilities to distributed projects could result in unnecessarily burdensome environmental review.
Thank you for considering this comment. We look forward to participating during future opportunities for input on the PEIS.
Sincerely,
Andrés Mejía
Government Affairs Associate, OneEnergy Renewables
andy.mejia@oneenergyrenewables.com↓
OneEnergy Development, LLC ("OneEnergy Renewables") is a solar development company headquartered in Seattle, Washington. We have developed over 120 MW of solar projects within the state and a...↓re hoping to build out a local storage portfolio.
We appreciate the opportunity to comment on the scoping document and support Ecology's efforts to develop a programmatic environmental analysis of stand-alone, utility-scale battery energy storage systems (BESS).
Section 3.1.2 (page 16) of the draft scoping document sorts BESS into two classes by power capacity: residential/commercial facilities below 1 MW, and utility-scale facilities of 1 MW or more. The document proposes focusing the PEIS on the utility-scale class, and Ecology states that it will determine the specific type of facility to be evaluated after considering scoping input.
We recommend Ecology disaggregate and study large-scale facilities (over 50MW) and distributed facilities (1-50MW) independently. The environmental impacts associated with these can vary greatly, and ascribing the attributes of large-scale facilities to distributed projects could result in unnecessarily burdensome environmental review.
Thank you for considering this comment. We look forward to participating during future opportunities for input on the PEIS.
Sincerely,
Andrés Mejía
Government Affairs Associate, OneEnergy Renewables
andy.mejia@oneenergyrenewables.com↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Joseph Hannan and I live at 7441 Raven Ave SE, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie, WA project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Joseph Hannan
7441 Raven Ave SE, Snoqualmie, WA↓
My name is Joseph Hannan and I live at 7441 Raven Ave SE, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie, WA project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Joseph Hannan
7441 Raven Ave SE, Snoqualmie, WA↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Jared Smith and I live at 8525 381st pl SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion b...↓attery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My children attend school near a proposed stand-alone BESS site, at Snoqualmie Elementary. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jared Smith
8525 381st pl SE↓
My name is Jared Smith and I live at 8525 381st pl SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion b...↓attery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My children attend school near a proposed stand-alone BESS site, at Snoqualmie Elementary. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Jared Smith
8525 381st pl SE↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Sarah Young and I live at 8525 381st pl SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion b...↓attery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My children attend school near a proposed stand-alone BESS site, at Snoqualmie Elementary. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sarah Young
8525 381st pl SE↓
My name is Sarah Young and I live at 8525 381st pl SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-ion b...↓attery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the Snoqualmie project. My children attend school near a proposed stand-alone BESS site, at Snoqualmie Elementary. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sarah Young
8525 381st pl SE↓
No attachments
Public Comment Regarding the Washington State Programmatic Environmental Impact Statement for Utility-Scale Battery Energy Storage Systems
To the Washington State Department of Ecology:
I am writing as a resident of the Snoqualmie Valley and as a mot...↓her who has called the City of Snoqualmie home for approximately 20 years. I am submitting this comment because I believe the proposed statewide evaluation of utility-scale battery energy storage systems must fully examine what happens when large-scale lithium-ion battery facilities are proposed directly adjacent to established communities, parks, forests, wildlife habitat, trails, homes, and the places where children live and play.
For me, this is not an abstract environmental issue. This is my home.
My family has lived in Snoqualmie for 20 years. My four children have had the opportunity to grow up here surrounded by an exceptional school district, history, forests, trails, parks, and the remarkable natural beauty of the Snoqualmie Valley. They have been able to experience the kind of childhood that is becoming increasingly difficult to find—a childhood where nature is not simply something viewed from a distance, but something that is part of everyday life.
I know this forest personally.
The forest behind my home has been a gift throughout the years. From my own backyard, I have witnessed wild turkey, quail, owls, a pileated woodpecker, bear, bobcat, and deer. I have watched wildlife move through a landscape that is also deeply intertwined with the human community.
I have even had a little girl emerge from the forest and sit on the swings in my backyard after becoming separated from her group. As it turned out, she was in my son's kindergarten class. I have had people traveling the trail make their way into my backyard to ask for directions. And I have been the person walking those same trails, becoming completely lost in the wonder of the trees.
That forest is not an empty piece of land. It provides joy. It provides education. It provides exploration. It provides peace. It provides connection. It provides habitat. And, for many people in this community, it provides something increasingly precious: hope.
Over the two decades I have lived here, I have also watched Snoqualmie change. I have watched construction and tree removal alter the landscape, and I have personally noticed that the wildlife visiting my backyard has become less frequent.
That experience has taught me something important: environmental impacts do not always arrive as one dramatic event. Sometimes they happen incrementally—one tree, one parcel, one construction project, one habitat disturbance at a time—until the community eventually realizes that something irreplaceable has been lost.
That is why I am deeply concerned about the continued movement toward large-scale industrial development in locations immediately adjacent to our established community.
The proposed Cascadia Ridge Resiliency Energy Storage project illustrates the importance of this statewide review. The proposal is for a 130-megawatt utility-scale battery energy storage facility on up to approximately 30 acres within roughly 45 acres of land just south of (touching the boundary) Fisher Creek Park, across Snoqualmie Parkway from Snoqualmie Ridge, in unincorporated King County.
Although the proposed project is outside Snoqualmie's municipal boundaries, its proximity means that the people, parks, trails, homes, wildlife, roads, emergency responders, and community spaces of Snoqualmie are directly relevant to the discussion.
This is precisely why I believe Ecology's statewide PEIS must examine not only whether BESS facilities can be engineered to operate safely under normal conditions, but also whether certain locations create unacceptable or substantially different risks because of their surrounding environment and population.
Children and Community Safety
I am the mother of four children. My youngest two are now approaching the age when they will leave the nest, but that does not lessen my responsibility for the children who will grow up here after mine are gone. I believe we have a responsibility to protect the children of our entire community—not simply our own.
Fisher Creek Park is one of the places where Snoqualmie children gather to play, laugh, explore, and build memories. Our trails are used by families, walkers, runners, cyclists, and people simply looking for a moment of peace in nature.
When evaluating utility-scale lithium-ion battery facilities, I believe proximity to children, homes, parks, schools, trails, and other heavily used community spaces must be treated as a significant environmental and public-safety consideration.
The question should not simply be:
Can a battery facility be built here?
The question should also be:
Is this an appropriate place for a facility of this scale and technology, given everything that surrounds it?
Fire, Air Quality, Emergency Response, and Environmental Consequences
I am particularly concerned about the consequences of a serious battery failure, including thermal runaway and fire.
Ecology itself has identified potential concerns associated with battery storage, including hazardous air emissions risks for emergency responders if batteries are damaged or fail, increased wildfire danger, noise, and limitations related to fire response. Ecology has also stated that the purpose of this PEIS is to examine potential impacts, identify mitigation measures, and identify gaps in regulations, codes, and emergency response.
I strongly urge Ecology to examine these issues with the assumption that prevention and mitigation are not the same thing as elimination of risk.
A facility may have monitoring systems, alarms, fire suppression equipment, trained responders, and other safeguards. Those measures are important. But the existence of safeguards should not end the environmental analysis.
Ecology should also ask:
• What happens when those safeguards fail?
• What happens when multiple battery units are involved?
• What hazardous substances may be released during a catastrophic battery fire?
• What happens to surrounding air quality?
• What happens to soil, surface water, groundwater, wetlands, vegetation, and wildlife?
• What happens to people living, walking, working, or playing nearby?
• What is the evacuation plan?
• How quickly can emergency responders access the facility?
• What resources are required from local fire departments?
• Can local emergency-response agencies realistically sustain the demands of a large-scale BESS incident?
• What happens when smoke, fire, or hazardous conditions affect surrounding roads and neighborhoods?
• Who is responsible for long-term environmental monitoring and cleanup?
• Who pays when the consequences extend beyond the facility's fence line?
• What happens to the community if an incident makes nearby land unsafe or unusable for an extended period?
These questions deserve rigorous scientific analysis before this technology becomes normalized in locations adjacent to communities.
Wildlife and Forest Habitat
My concern is not limited to the immediate footprint of a facility. The surrounding forest is an ecosystem. The wildlife I have personally observed—bear, bobcat, deer, turkey, quail, owls, and pileated woodpeckers—is evidence of the living community that exists here.
I ask Ecology to examine the cumulative effects of BESS development on habitat, wildlife movement, vegetation, forest fragmentation, water resources, noise, lighting, construction disturbance, and the potential consequences of a catastrophic fire or release.
We cannot evaluate the loss of habitat simply by calculating the number of acres cleared.
An acre of forest is not merely an acre. It is trees. It is soil. It is water. It is food. It is shelter. It is nesting habitat. It is wildlife movement. It is shade. It is carbon storage. It is part of an interconnected ecosystem. And it is also part of the identity of the community surrounding it.
Snoqualmie Is Different
Snoqualmie is not simply another location on a map where an industrial facility can be placed because electrical infrastructure happens to be nearby.
Snoqualmie has a history, a landscape, and a community identity that people have chosen to protect and preserve.
I have spent years walking our trails and hiking our mountains. I have walked past community gardens and parks filled with children laughing and playing. I have encountered deer and horses along the trails. I have experienced the quietness of the forest and the sense of connection that comes from living alongside it.
This is what makes Snoqualmie special. It is the history. It is the beauty. It is the forest. It is the wildlife. It is the trails. It is the children. It is the Valley of The People Of The Moon. It is the people who come together when something important is at stake. It is a community that understands that the natural environment is not separate from the community—it is part of it.
Economic Value Cannot Be the Only Measure
I understand that utility-scale battery storage can provide services to the electrical grid and that developers identify economic and energy benefits associated with these facilities.
Those benefits should be examined. But they should be examined alongside the full environmental and community costs.
When a project is described in terms of financial investment, tax revenue, jobs, or grid benefits, I believe we must also ask what value is being assigned to clean air, healthy forests, wildlife habitat, children's safety, emergency-response capacity, peace of mind, and the long-term character of a community.
If financial assurance is proposed as protection against potential losses, Ecology should examine whether that assurance is actually proportional to the potential consequences of a catastrophic event.
A dollar amount can compensate for certain documented losses. It cannot replace a human life.
It cannot restore a childhood memory. It cannot bring back a destroyed forest overnight. It cannot restore a wildlife habitat exactly as it was. It cannot erase exposure to hazardous smoke.
It cannot purchase back a community's sense of safety. Life is priceless and cannot be bought.
What I Am Asking Ecology to Consider
I respectfully ask the Department of Ecology to make the statewide BESS PEIS as comprehensive as possible and to give particular attention to facilities proposed near established communities and environmentally sensitive areas.
I ask that the study thoroughly evaluate:
1. Fire and thermal-runaway risks, including worst-case and cascading scenarios.
2. Air emissions and toxic substances associated with battery fires and emergency response.
3. Impacts to surface water, groundwater, soil, wetlands, and wildlife following fires or fire suppression.
4. Wildlife habitat and forest fragmentation, including cumulative impacts.
5. Proximity to homes, parks, schools, trails, and other populated areas.
6. Emergency-response capacity, including whether local agencies have sufficient equipment, staffing, training, and resources.
7. Evacuation requirements and realistic evacuation scenarios.
8. Long-term monitoring, decommissioning, and environmental cleanup.
9. Financial responsibility and liability, including whether proposed financial assurances could realistically address worst-case consequences.
10. Cumulative impacts when BESS facilities are developed in or near communities already experiencing substantial growth and habitat loss.
11. Alternative siting considerations, including whether utility-scale BESS facilities should be located farther from homes, children, parks, forests, and other sensitive uses when suitable alternatives exist.
12. Whether current regulations and safety standards are sufficient for the scale of BESS facilities now being proposed.
Most importantly, I ask Ecology to examine where these facilities should be located, not merely how they can be mitigated after a location has already been selected.
My Personal Position
I know that one person cannot stop every change that comes to a community.
But communities are built by people who are willing to speak when something matters.
I am one of those people.
I have lived in Snoqualmie for 20 years. I have raised my children here. I have walked these forests. I have watched wildlife from my backyard. I have watched my children experience the parks, trails, schools, and natural beauty of this Valley.
I have also watched pieces of that natural environment disappear as development has continued.
I do not want to look back years from now and wonder why we failed to speak when we still had the opportunity to protect what remained.
We have a choice about what kind of communities we build.
We can treat forests, wildlife, children, parks, and the natural landscape as obstacles to development.
Or we can recognize them as assets that have intrinsic value and that deserve to be protected.
I am asking the Washington State Department of Ecology to choose the latter in its evaluation of utility-scale battery energy storage systems.
I am asking you to look beyond the fence line of a proposed facility. Look at the homes. Look at the children. Look at Fisher Creek Park. Look at the trails. Look at the forest. Look at the wildlife.
Look at the people who have built their lives here.
And please remember that environmental protection is not simply about protecting land.
It is about protecting the living community that depends upon that land.
I am unequivocally opposed to placing the proposed large-scale BESS facility adjacent to the Snoqualmie community, and I strongly urge the Department of Ecology to ensure that the statewide PEIS fully examines the environmental, health, safety, emergency-response, wildlife, and community consequences associated with utility-scale lithium-ion battery energy storage—particularly when these facilities are proposed immediately alongside established communities and sensitive natural areas.
Thank you for accepting and considering my comments.
Respectfully,
Christina Stembler
Resident of Snoqualmie Valley, Washington↓
To the Washington State Department of Ecology:
I am writing as a resident of the Snoqualmie Valley and as a mot...↓her who has called the City of Snoqualmie home for approximately 20 years. I am submitting this comment because I believe the proposed statewide evaluation of utility-scale battery energy storage systems must fully examine what happens when large-scale lithium-ion battery facilities are proposed directly adjacent to established communities, parks, forests, wildlife habitat, trails, homes, and the places where children live and play.
For me, this is not an abstract environmental issue. This is my home.
My family has lived in Snoqualmie for 20 years. My four children have had the opportunity to grow up here surrounded by an exceptional school district, history, forests, trails, parks, and the remarkable natural beauty of the Snoqualmie Valley. They have been able to experience the kind of childhood that is becoming increasingly difficult to find—a childhood where nature is not simply something viewed from a distance, but something that is part of everyday life.
I know this forest personally.
The forest behind my home has been a gift throughout the years. From my own backyard, I have witnessed wild turkey, quail, owls, a pileated woodpecker, bear, bobcat, and deer. I have watched wildlife move through a landscape that is also deeply intertwined with the human community.
I have even had a little girl emerge from the forest and sit on the swings in my backyard after becoming separated from her group. As it turned out, she was in my son's kindergarten class. I have had people traveling the trail make their way into my backyard to ask for directions. And I have been the person walking those same trails, becoming completely lost in the wonder of the trees.
That forest is not an empty piece of land. It provides joy. It provides education. It provides exploration. It provides peace. It provides connection. It provides habitat. And, for many people in this community, it provides something increasingly precious: hope.
Over the two decades I have lived here, I have also watched Snoqualmie change. I have watched construction and tree removal alter the landscape, and I have personally noticed that the wildlife visiting my backyard has become less frequent.
That experience has taught me something important: environmental impacts do not always arrive as one dramatic event. Sometimes they happen incrementally—one tree, one parcel, one construction project, one habitat disturbance at a time—until the community eventually realizes that something irreplaceable has been lost.
That is why I am deeply concerned about the continued movement toward large-scale industrial development in locations immediately adjacent to our established community.
The proposed Cascadia Ridge Resiliency Energy Storage project illustrates the importance of this statewide review. The proposal is for a 130-megawatt utility-scale battery energy storage facility on up to approximately 30 acres within roughly 45 acres of land just south of (touching the boundary) Fisher Creek Park, across Snoqualmie Parkway from Snoqualmie Ridge, in unincorporated King County.
Although the proposed project is outside Snoqualmie's municipal boundaries, its proximity means that the people, parks, trails, homes, wildlife, roads, emergency responders, and community spaces of Snoqualmie are directly relevant to the discussion.
This is precisely why I believe Ecology's statewide PEIS must examine not only whether BESS facilities can be engineered to operate safely under normal conditions, but also whether certain locations create unacceptable or substantially different risks because of their surrounding environment and population.
Children and Community Safety
I am the mother of four children. My youngest two are now approaching the age when they will leave the nest, but that does not lessen my responsibility for the children who will grow up here after mine are gone. I believe we have a responsibility to protect the children of our entire community—not simply our own.
Fisher Creek Park is one of the places where Snoqualmie children gather to play, laugh, explore, and build memories. Our trails are used by families, walkers, runners, cyclists, and people simply looking for a moment of peace in nature.
When evaluating utility-scale lithium-ion battery facilities, I believe proximity to children, homes, parks, schools, trails, and other heavily used community spaces must be treated as a significant environmental and public-safety consideration.
The question should not simply be:
Can a battery facility be built here?
The question should also be:
Is this an appropriate place for a facility of this scale and technology, given everything that surrounds it?
Fire, Air Quality, Emergency Response, and Environmental Consequences
I am particularly concerned about the consequences of a serious battery failure, including thermal runaway and fire.
Ecology itself has identified potential concerns associated with battery storage, including hazardous air emissions risks for emergency responders if batteries are damaged or fail, increased wildfire danger, noise, and limitations related to fire response. Ecology has also stated that the purpose of this PEIS is to examine potential impacts, identify mitigation measures, and identify gaps in regulations, codes, and emergency response.
I strongly urge Ecology to examine these issues with the assumption that prevention and mitigation are not the same thing as elimination of risk.
A facility may have monitoring systems, alarms, fire suppression equipment, trained responders, and other safeguards. Those measures are important. But the existence of safeguards should not end the environmental analysis.
Ecology should also ask:
• What happens when those safeguards fail?
• What happens when multiple battery units are involved?
• What hazardous substances may be released during a catastrophic battery fire?
• What happens to surrounding air quality?
• What happens to soil, surface water, groundwater, wetlands, vegetation, and wildlife?
• What happens to people living, walking, working, or playing nearby?
• What is the evacuation plan?
• How quickly can emergency responders access the facility?
• What resources are required from local fire departments?
• Can local emergency-response agencies realistically sustain the demands of a large-scale BESS incident?
• What happens when smoke, fire, or hazardous conditions affect surrounding roads and neighborhoods?
• Who is responsible for long-term environmental monitoring and cleanup?
• Who pays when the consequences extend beyond the facility's fence line?
• What happens to the community if an incident makes nearby land unsafe or unusable for an extended period?
These questions deserve rigorous scientific analysis before this technology becomes normalized in locations adjacent to communities.
Wildlife and Forest Habitat
My concern is not limited to the immediate footprint of a facility. The surrounding forest is an ecosystem. The wildlife I have personally observed—bear, bobcat, deer, turkey, quail, owls, and pileated woodpeckers—is evidence of the living community that exists here.
I ask Ecology to examine the cumulative effects of BESS development on habitat, wildlife movement, vegetation, forest fragmentation, water resources, noise, lighting, construction disturbance, and the potential consequences of a catastrophic fire or release.
We cannot evaluate the loss of habitat simply by calculating the number of acres cleared.
An acre of forest is not merely an acre. It is trees. It is soil. It is water. It is food. It is shelter. It is nesting habitat. It is wildlife movement. It is shade. It is carbon storage. It is part of an interconnected ecosystem. And it is also part of the identity of the community surrounding it.
Snoqualmie Is Different
Snoqualmie is not simply another location on a map where an industrial facility can be placed because electrical infrastructure happens to be nearby.
Snoqualmie has a history, a landscape, and a community identity that people have chosen to protect and preserve.
I have spent years walking our trails and hiking our mountains. I have walked past community gardens and parks filled with children laughing and playing. I have encountered deer and horses along the trails. I have experienced the quietness of the forest and the sense of connection that comes from living alongside it.
This is what makes Snoqualmie special. It is the history. It is the beauty. It is the forest. It is the wildlife. It is the trails. It is the children. It is the Valley of The People Of The Moon. It is the people who come together when something important is at stake. It is a community that understands that the natural environment is not separate from the community—it is part of it.
Economic Value Cannot Be the Only Measure
I understand that utility-scale battery storage can provide services to the electrical grid and that developers identify economic and energy benefits associated with these facilities.
Those benefits should be examined. But they should be examined alongside the full environmental and community costs.
When a project is described in terms of financial investment, tax revenue, jobs, or grid benefits, I believe we must also ask what value is being assigned to clean air, healthy forests, wildlife habitat, children's safety, emergency-response capacity, peace of mind, and the long-term character of a community.
If financial assurance is proposed as protection against potential losses, Ecology should examine whether that assurance is actually proportional to the potential consequences of a catastrophic event.
A dollar amount can compensate for certain documented losses. It cannot replace a human life.
It cannot restore a childhood memory. It cannot bring back a destroyed forest overnight. It cannot restore a wildlife habitat exactly as it was. It cannot erase exposure to hazardous smoke.
It cannot purchase back a community's sense of safety. Life is priceless and cannot be bought.
What I Am Asking Ecology to Consider
I respectfully ask the Department of Ecology to make the statewide BESS PEIS as comprehensive as possible and to give particular attention to facilities proposed near established communities and environmentally sensitive areas.
I ask that the study thoroughly evaluate:
1. Fire and thermal-runaway risks, including worst-case and cascading scenarios.
2. Air emissions and toxic substances associated with battery fires and emergency response.
3. Impacts to surface water, groundwater, soil, wetlands, and wildlife following fires or fire suppression.
4. Wildlife habitat and forest fragmentation, including cumulative impacts.
5. Proximity to homes, parks, schools, trails, and other populated areas.
6. Emergency-response capacity, including whether local agencies have sufficient equipment, staffing, training, and resources.
7. Evacuation requirements and realistic evacuation scenarios.
8. Long-term monitoring, decommissioning, and environmental cleanup.
9. Financial responsibility and liability, including whether proposed financial assurances could realistically address worst-case consequences.
10. Cumulative impacts when BESS facilities are developed in or near communities already experiencing substantial growth and habitat loss.
11. Alternative siting considerations, including whether utility-scale BESS facilities should be located farther from homes, children, parks, forests, and other sensitive uses when suitable alternatives exist.
12. Whether current regulations and safety standards are sufficient for the scale of BESS facilities now being proposed.
Most importantly, I ask Ecology to examine where these facilities should be located, not merely how they can be mitigated after a location has already been selected.
My Personal Position
I know that one person cannot stop every change that comes to a community.
But communities are built by people who are willing to speak when something matters.
I am one of those people.
I have lived in Snoqualmie for 20 years. I have raised my children here. I have walked these forests. I have watched wildlife from my backyard. I have watched my children experience the parks, trails, schools, and natural beauty of this Valley.
I have also watched pieces of that natural environment disappear as development has continued.
I do not want to look back years from now and wonder why we failed to speak when we still had the opportunity to protect what remained.
We have a choice about what kind of communities we build.
We can treat forests, wildlife, children, parks, and the natural landscape as obstacles to development.
Or we can recognize them as assets that have intrinsic value and that deserve to be protected.
I am asking the Washington State Department of Ecology to choose the latter in its evaluation of utility-scale battery energy storage systems.
I am asking you to look beyond the fence line of a proposed facility. Look at the homes. Look at the children. Look at Fisher Creek Park. Look at the trails. Look at the forest. Look at the wildlife.
Look at the people who have built their lives here.
And please remember that environmental protection is not simply about protecting land.
It is about protecting the living community that depends upon that land.
I am unequivocally opposed to placing the proposed large-scale BESS facility adjacent to the Snoqualmie community, and I strongly urge the Department of Ecology to ensure that the statewide PEIS fully examines the environmental, health, safety, emergency-response, wildlife, and community consequences associated with utility-scale lithium-ion battery energy storage—particularly when these facilities are proposed immediately alongside established communities and sensitive natural areas.
Thank you for accepting and considering my comments.
Respectfully,
Christina Stembler
Resident of Snoqualmie Valley, Washington↓
Attachments:
The Ecology study should define "suitable" areas using safety as a guide. Will it be too close to underground water or rivers that could be contaminated if there were a fire, are there adequate resources (personnel, water) immediately available to e...↓xtinguish any potential fire, if near populated areas are there sufficient exit routes to quickly and safely evacuate the population, what is the safety record of the batteries and the installer / operator, any possibility of any potential fire spreading into forested area, and what would happen in the event of a major earthquake are a few things I feel need to be considered.↓
No attachments
A battery thermal-runaway event must not be evaluated solely as a fire-code or emergency-response matter when the credible consequences of that event may affect SEPA environmental elements.
The PEIS should clearly distinguish fire-code compliance fr...↓om environmental review. Compliance with the International Fire Code, NFPA 855, UL 9540, UL 9540A, or approval by a local fire authority does not by itself evaluate probable impacts to air quality, soils, surface water, groundwater, critical aquifer recharge areas, wetlands, fish and wildlife, neighboring communities, transportation, evacuation routes, or public services.
Ecology should specifically address the risk that project-level lead agencies may characterize thermal-runaway consequences primarily as fire-safety matters and defer analysis of their environmental effects to later Hazard Mitigation Analyses, Emergency Response Plans, fire permits, building permits, or construction-stage review.
Where those consequences are reasonably foreseeable and relevant to determining whether a proposal may have significant adverse environmental impacts, the environmental analysis should occur early enough to inform the SEPA threshold determination and any discretionary land-use approval. Later fire-code or building-code review should supplement, not substitute for, the environmental review required under SEPA.
The PEIS should therefore provide clear guidance identifying which consequences of credible BESS failure scenarios must be addressed during SEPA review, even when separate fire, building, or emergency-response regulations also apply.
An environmental consequence does not cease to be a SEPA consequence merely because its initiating event is regulated by the fire code.↓
The PEIS should clearly distinguish fire-code compliance fr...↓om environmental review. Compliance with the International Fire Code, NFPA 855, UL 9540, UL 9540A, or approval by a local fire authority does not by itself evaluate probable impacts to air quality, soils, surface water, groundwater, critical aquifer recharge areas, wetlands, fish and wildlife, neighboring communities, transportation, evacuation routes, or public services.
Ecology should specifically address the risk that project-level lead agencies may characterize thermal-runaway consequences primarily as fire-safety matters and defer analysis of their environmental effects to later Hazard Mitigation Analyses, Emergency Response Plans, fire permits, building permits, or construction-stage review.
Where those consequences are reasonably foreseeable and relevant to determining whether a proposal may have significant adverse environmental impacts, the environmental analysis should occur early enough to inform the SEPA threshold determination and any discretionary land-use approval. Later fire-code or building-code review should supplement, not substitute for, the environmental review required under SEPA.
The PEIS should therefore provide clear guidance identifying which consequences of credible BESS failure scenarios must be addressed during SEPA review, even when separate fire, building, or emergency-response regulations also apply.
An environmental consequence does not cease to be a SEPA consequence merely because its initiating event is regulated by the fire code.↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Donna Anderson and I live at 1360 SW 13th Place in North Bend. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on I-90, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Donna Anderson
1360 SW 13th Place
North Bend, WA 98045↓
My name is Donna Anderson and I live at 1360 SW 13th Place in North Bend. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-s...↓cale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. I would like to see the study thoroughly examine the direct, indirect, and cumulative effects of how smoke settles into valleys, runoff reaches wells and streams, and what happens when there are several facilities on the same stretch of grid. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on I-90, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Donna Anderson
1360 SW 13th Place
North Bend, WA 98045↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Elliott Drury and I live at 7119 Cranberry CT SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at SMS. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Elliott Drury↓
My name is Elliott Drury and I live at 7119 Cranberry CT SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at SMS. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Elliott Drury↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Elliott Drury and I live at 7119 Cranberry CT SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at SMS. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Elliott Drury
7119 Cranberry CT SE↓
My name is Elliott Drury and I live at 7119 Cranberry CT SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study should look at what a multi-day battery fire demands from local fire, hazmat, hospital, and evacuation capacity, since Ecology could not say whether the burden on small rural fire districts can be fixed. The study should properly model whether neighbors can evacuate without breathing dangerous levels of toxic gas in places such as a valley that traps air, which is what the fire code requires. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My children attend school near a proposed stand-alone BESS site, at SMS. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Elliott Drury
7119 Cranberry CT SE↓
No attachments
See attached comment letter.
Attachments:
As a purchasing agent years ago at Master Specialties, Costa Mesa, CA - sole source for nuclear power plant switches, we had a disqualified vendor list. I purchased metals, metal plating, rfi screens, screw machine parts etc. per DOD regulations. A t...↓iny contact was purchased using a large blue print detailing the Mil-spec requirements and list of engineering orders detailing complete traceability from the original design through each corrective action made to the design of its current state. Vendors provided certification of the mountain where metal was mined from. We had receiving inspection with an engineer receiving parts, a radio active isotope was used to measure the thickness of precious metal plating. I disqualified one plater after touring the facility and seeing the office where they claimed to operate their QA process which only had an empty desk and no documents.
Tesla, a major manufacturer of BESS batteries is listed as a potential vendor for the proposed BESS facility in Snoqualmie, Tesla should be disqualified to be a vendor for anything:
https://sfdistrictattorney.org/tesla-inc-settles-environmental-enforcement-action-brought-by-california-district-attorneys/
TESLA, INC. SETTLES ENVIRONMENTAL ENFORCEMENT ACTION BROUGHT BY CALIFORNIA DISTRICT ATTORNEYS
• February 1, 2024
Electric car company illegally disposed of hazardous waste at its service centers, energy centers, and its Fremont factory.
San Francisco, CA – San Francisco District Attorney Brooke Jenkins, along with 24 other District Attorneys throughout California, announced today that a judge in San Joaquin County has ordered Tesla, Inc. to pay $1.5 million as part of a settlement of a civil environmental prosecution alleging the electric car company illegally disposed of hazardous waste at its car service centers, energy centers, and its factory in Fremont.
"While electric vehicles may benefit the environment, the manufacturing and servicing of these vehicles still generates many harmful waste streams," said District Attorney Brooke Jenkins. "Today's settlement against Tesla, Inc. serves to provide a cleaner environment for citizens throughout the state by preventing the contamination of our precious natural resources when hazardous waste is mismanaged and unlawfully disposed. We are proud to work with our district attorney partners to enforce California's environmental laws to ensure these hazardous wastes are handled properly."
In the complaint filed in San Joaquin County, prosecutors alleged Tesla, Inc. illegally disposed of hazardous waste generated during its servicing and manufacturing of its electric vehicles in violation of California law establishing the proper control, storage, management, and disposal of hazardous waste. Tesla, Inc., a Delaware Corporation, currently owns and operates approximately 57 car service centers and 18 solar energy facilities throughout California. It also manufactures electric vehicles at its Fremont Factory in Alameda County. The case is brought by the San Francisco District Attorney's Office and 24 other California District Attorneys' Offices where Tesla, Inc.'s factory, car service centers, and energy locations are located.
The investigation, initiated by the San Francisco District Attorney's Office Environmental Division, began in 2018 when San Francisco District Attorney investigators conducted undercover inspections of Tesla, Inc.'s trash containers at its car service centers, which revealed the illegal disposal of numerous used hazardous automotive components (i.e., lubricating oils, brake cleaners, lead acid and other batteries, aerosols, antifreeze, waste solvents and other cleaners, electronic waste, waste paint, and debris contaminated with the above).
Following this discovery, District Attorney investigators from Alameda, Monterey, Orange, Placer, Riverside, San Diego, and San Joaquin counties conducted additional inspections at Tesla, Inc.'s car service centers throughout California and found similar unlawful disposals. Alameda County District Attorney investigators also conducted waste inspections of trash containers at the Fremont Factory and found Tesla's unlawful disposal of additional hazardous wastes, including metal car panel welding spatter waste (which can contain copper), waste paint mix cups produced during paint repair and wipes/debris contaminated with primer.
Tesla, Inc. cooperated with the District Attorneys' investigation and took steps to improve its compliance with the environmental protection laws brought to its attention by the prosecutors. After Tesla was notified of the issues, they began quarantining and screening trash containers for hazardous waste at all of its service centers before trash was brought to the landfill.
As part of the settlement, Tesla, Inc. is ordered to pay $1.3 million in civil penalties and $200,000 to reimburse the costs of the investigation. Tesla, Inc. is also ordered to comply with a detailed injunction for five years. Injunctive compliance measures include proper training of employees and the hiring of a third party to conduct annual waste audits of its trash containers at ten percent of its facilities. These audits will occur each year for five years and auditors will examine trash containers for hazardous waste.
__________________________________________________________
Tesla Powerwalls Remotely Disabled — Thousands Left With Dead Batteries
https://youtu.be/b5cSicjTODQ?si=XSTdnM30uiCvZjP1
___________________________________________________________
Musk ordered shutdown of Starlink satellite service as Ukraine retook territory from Russia
https://www.reuters.com/investigations/musk-ordered-shutdown-starlink-satellite-service-ukraine-retook-territory-russia-2025-07-25/
Musk acknowledges he turned off Starlink internet access last year during Ukraine attack on Russia military
https://thehill.com/policy/defense/4193788-musk-acknowledges-he-turned-off-starlink-internet-access-last-year-during-ukraine-attack-on-russia-military/
Legal affairs of Elon Musk - Wikipedia
https://en.wikipedia.org/wiki/Legal_affairs_of_Elon_Musk
_________________________________________________________________
Retired EV Batteries Get Second Life on the Grid
↓
Tesla, a major manufacturer of BESS batteries is listed as a potential vendor for the proposed BESS facility in Snoqualmie, Tesla should be disqualified to be a vendor for anything:
https://sfdistrictattorney.org/tesla-inc-settles-environmental-enforcement-action-brought-by-california-district-attorneys/
TESLA, INC. SETTLES ENVIRONMENTAL ENFORCEMENT ACTION BROUGHT BY CALIFORNIA DISTRICT ATTORNEYS
• February 1, 2024
Electric car company illegally disposed of hazardous waste at its service centers, energy centers, and its Fremont factory.
San Francisco, CA – San Francisco District Attorney Brooke Jenkins, along with 24 other District Attorneys throughout California, announced today that a judge in San Joaquin County has ordered Tesla, Inc. to pay $1.5 million as part of a settlement of a civil environmental prosecution alleging the electric car company illegally disposed of hazardous waste at its car service centers, energy centers, and its factory in Fremont.
"While electric vehicles may benefit the environment, the manufacturing and servicing of these vehicles still generates many harmful waste streams," said District Attorney Brooke Jenkins. "Today's settlement against Tesla, Inc. serves to provide a cleaner environment for citizens throughout the state by preventing the contamination of our precious natural resources when hazardous waste is mismanaged and unlawfully disposed. We are proud to work with our district attorney partners to enforce California's environmental laws to ensure these hazardous wastes are handled properly."
In the complaint filed in San Joaquin County, prosecutors alleged Tesla, Inc. illegally disposed of hazardous waste generated during its servicing and manufacturing of its electric vehicles in violation of California law establishing the proper control, storage, management, and disposal of hazardous waste. Tesla, Inc., a Delaware Corporation, currently owns and operates approximately 57 car service centers and 18 solar energy facilities throughout California. It also manufactures electric vehicles at its Fremont Factory in Alameda County. The case is brought by the San Francisco District Attorney's Office and 24 other California District Attorneys' Offices where Tesla, Inc.'s factory, car service centers, and energy locations are located.
The investigation, initiated by the San Francisco District Attorney's Office Environmental Division, began in 2018 when San Francisco District Attorney investigators conducted undercover inspections of Tesla, Inc.'s trash containers at its car service centers, which revealed the illegal disposal of numerous used hazardous automotive components (i.e., lubricating oils, brake cleaners, lead acid and other batteries, aerosols, antifreeze, waste solvents and other cleaners, electronic waste, waste paint, and debris contaminated with the above).
Following this discovery, District Attorney investigators from Alameda, Monterey, Orange, Placer, Riverside, San Diego, and San Joaquin counties conducted additional inspections at Tesla, Inc.'s car service centers throughout California and found similar unlawful disposals. Alameda County District Attorney investigators also conducted waste inspections of trash containers at the Fremont Factory and found Tesla's unlawful disposal of additional hazardous wastes, including metal car panel welding spatter waste (which can contain copper), waste paint mix cups produced during paint repair and wipes/debris contaminated with primer.
Tesla, Inc. cooperated with the District Attorneys' investigation and took steps to improve its compliance with the environmental protection laws brought to its attention by the prosecutors. After Tesla was notified of the issues, they began quarantining and screening trash containers for hazardous waste at all of its service centers before trash was brought to the landfill.
As part of the settlement, Tesla, Inc. is ordered to pay $1.3 million in civil penalties and $200,000 to reimburse the costs of the investigation. Tesla, Inc. is also ordered to comply with a detailed injunction for five years. Injunctive compliance measures include proper training of employees and the hiring of a third party to conduct annual waste audits of its trash containers at ten percent of its facilities. These audits will occur each year for five years and auditors will examine trash containers for hazardous waste.
__________________________________________________________
Tesla Powerwalls Remotely Disabled — Thousands Left With Dead Batteries
https://youtu.be/b5cSicjTODQ?si=XSTdnM30uiCvZjP1
___________________________________________________________
Musk ordered shutdown of Starlink satellite service as Ukraine retook territory from Russia
https://www.reuters.com/investigations/musk-ordered-shutdown-starlink-satellite-service-ukraine-retook-territory-russia-2025-07-25/
Musk acknowledges he turned off Starlink internet access last year during Ukraine attack on Russia military
https://thehill.com/policy/defense/4193788-musk-acknowledges-he-turned-off-starlink-internet-access-last-year-during-ukraine-attack-on-russia-military/
Legal affairs of Elon Musk - Wikipedia
https://en.wikipedia.org/wiki/Legal_affairs_of_Elon_Musk
_________________________________________________________________
Retired EV Batteries Get Second Life on the Grid
↓
Please find my attached 55 page Public Comment regarding Ecology's Scoping for Battery Energy Storage Systems Programmatic Environmental Impact Statement. I would like to become a party of record for this matter and be notified of any documents, hear...↓ings, or decisions at my email address.
Please take this matter seriously as the consequences to the environment, water supply, communities, schools, families, and individuals could be catastrophic.
There is enough available evidence from 100s of BESS fires to prove that BESS have significant impacts- even though evidence is now just coming to light as developers/owners/operators have successfully hidden the true impacts by telling us/everyone "everything is safe" or "nothing to see here" and providing the results they paid Environmental firms to get that favored them exclusively.
Thank you for this opportunity to comment!
James↓
Please take this matter seriously as the consequences to the environment, water supply, communities, schools, families, and individuals could be catastrophic.
There is enough available evidence from 100s of BESS fires to prove that BESS have significant impacts- even though evidence is now just coming to light as developers/owners/operators have successfully hidden the true impacts by telling us/everyone "everything is safe" or "nothing to see here" and providing the results they paid Environmental firms to get that favored them exclusively.
Thank you for this opportunity to comment!
James↓
Attachments:
MOSS Landing recently re-ignited a year after the last large battery fire. Last year was the fourth time that MOSS Landing had a catastrophic failure. This year's failure was from the long arduous work that it takes to clean up defective batteries.
...↓
Moss Landing Battery Fire Reignites 20 Months Later
https://www.youtube.com/watch?v=9aHYNzMG7TA
Gateway Energy: Clean Up of America's (2nd...
https://www.youtube.com/watch?v=Vg2SFaycHDI
BESS fires: Residents Sue energy companies after massive toxic battery fire at Moss Landing power plant
https://ctif.org/news/bess-fires-residents-sue-energy-companies-after-massive-toxic-battery-fire-moss-landing-power
↓
...↓
Moss Landing Battery Fire Reignites 20 Months Later
https://www.youtube.com/watch?v=9aHYNzMG7TA
Gateway Energy: Clean Up of America's (2nd...
https://www.youtube.com/watch?v=Vg2SFaycHDI
BESS fires: Residents Sue energy companies after massive toxic battery fire at Moss Landing power plant
https://ctif.org/news/bess-fires-residents-sue-energy-companies-after-massive-toxic-battery-fire-moss-landing-power
↓
No attachments
MOSS Landing recently re-ignited a year after the last large battery fire. Last year was the fourth time that MOSS Landing had a catastrophic failure. This year's failure was from the long arduous work that it takes to clean up defective batteries.
...↓
Moss Landing Battery Fire Reignites 20 Months Later
https://www.youtube.com/watch?v=9aHYNzMG7TA
Gateway Energy: Clean Up of America's (2nd...
https://www.youtube.com/watch?v=Vg2SFaycHDI
BESS fires: Residents Sue energy companies after massive toxic battery fire at Moss Landing power plant
https://ctif.org/news/bess-fires-residents-sue-energy-companies-after-massive-toxic-battery-fire-moss-landing-power
↓
...↓
Moss Landing Battery Fire Reignites 20 Months Later
https://www.youtube.com/watch?v=9aHYNzMG7TA
Gateway Energy: Clean Up of America's (2nd...
https://www.youtube.com/watch?v=Vg2SFaycHDI
BESS fires: Residents Sue energy companies after massive toxic battery fire at Moss Landing power plant
https://ctif.org/news/bess-fires-residents-sue-energy-companies-after-massive-toxic-battery-fire-moss-landing-power
↓
No attachments
Often the explanation of how lithium batteries became defective includes "during shipping". When batteries have been banged around during shipping, it's hard to appreciate how significant those impacts are. The following video demonstrates how much d...↓amage can happen during transport. Before you consider this as not applicable, be aware that the BESS batteries cannot be tested completely to determine there's no damage to BESS batteries - damage is not obvious just by looking at its exterior. Imagine a BESS battery coming to western WA to be developed, the ship transporting the batteries will probably come from the same part of the world where seas are normally rough. For this video, 25% of the BESS batteries were identified as defective. If a BESS battery that looks OK from the exterior but potentially is defective and not labelled as such - do you pick it up at a port near Seattle? Do you drive through a tunnel? One BESS battery weighs roughly 21,000 pounds.
NTSB Report Released: Genius Star XI Battery Fire
https://www.youtube.com/watch?v=uxr2pCJrjNg
For more than two years, details about a major lithium-ion battery fire aboard a cargo ship near Alaska were vague. Now, the National Transportation Safety Board (NTSB) has released its final report.
This video breaks down the Genius Star XI incident, what was actually being shipped, and how a mechanical cargo-securing failure — not a mysterious battery defect — led to multiple BESS units breaking free, being damaged, and catching fire in heavy seas.
This wasn't just a battery fire. It was a mechanical failure that turned into one.
____________________________________________________
As I continued to "google" shipping and battery fire or lithium fire I discovered more agencies who are concerned about lithium fires on ships.
2023 07 Fremantle Highway.pdf
2025 06 23 Morning Midas sank.pdf
Fires at Sea The Hidden Dangers of Lithium-lon Batteries.pdf
Lithium-lon Battery Maritime Concerns.pdf
__________________________________________________
The NTSB report for the Genius Star XI Battery Fire
I reviewed a couple of sections:
HazMat Cargo Vessel Genius Star XI
Lithium-ion Battery Fires aboard Cargo Vessel Genius Star XI
https://www.ntsb.gov/investigations/Pages/DCA24FM013.aspx
↓
NTSB Report Released: Genius Star XI Battery Fire
https://www.youtube.com/watch?v=uxr2pCJrjNg
For more than two years, details about a major lithium-ion battery fire aboard a cargo ship near Alaska were vague. Now, the National Transportation Safety Board (NTSB) has released its final report.
This video breaks down the Genius Star XI incident, what was actually being shipped, and how a mechanical cargo-securing failure — not a mysterious battery defect — led to multiple BESS units breaking free, being damaged, and catching fire in heavy seas.
This wasn't just a battery fire. It was a mechanical failure that turned into one.
____________________________________________________
As I continued to "google" shipping and battery fire or lithium fire I discovered more agencies who are concerned about lithium fires on ships.
2023 07 Fremantle Highway.pdf
2025 06 23 Morning Midas sank.pdf
Fires at Sea The Hidden Dangers of Lithium-lon Batteries.pdf
Lithium-lon Battery Maritime Concerns.pdf
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The NTSB report for the Genius Star XI Battery Fire
I reviewed a couple of sections:
HazMat Cargo Vessel Genius Star XI
Lithium-ion Battery Fires aboard Cargo Vessel Genius Star XI
https://www.ntsb.gov/investigations/Pages/DCA24FM013.aspx
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To the Department of Ecology, Clean Energy Coordination:
My name is Karen Rockow and I currently reside at 36718 SE 86th St. Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-...↓alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am moved to comment because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require in order to reduce the harm.
I am requesting the study to identify specific, measurable protections a permit can require. Protections described "at a high level" are too vague and leave too much to interpretation and give my county nothing to write into a permit. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for your time and consideration regarding my concerns which are shared by many in Washington State. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Respectfully,
Karen Rockow
36718 SE 86th St. Snoqualmie, WA 98065↓
My name is Karen Rockow and I currently reside at 36718 SE 86th St. Snoqualmie, WA 98065. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-...↓alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am moved to comment because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require in order to reduce the harm.
I am requesting the study to identify specific, measurable protections a permit can require. Protections described "at a high level" are too vague and leave too much to interpretation and give my county nothing to write into a permit. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for your time and consideration regarding my concerns which are shared by many in Washington State. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Respectfully,
Karen Rockow
36718 SE 86th St. Snoqualmie, WA 98065↓
No attachments
Goodday. My name is David Pedersen and you speak of the MOSS landing fire par.#3 on the Draft Scoping for Battery Energy Storage PEIS, was described as a minor event from the testing done at that time. The consulting firm that was hired by the county...↓, tested the water and soil measured at deeper levels than the test's done by Scientest's at surface levels. The results from those tests conflict with each other. Please see attachment BESS Scientist's Pre...r The first fire at MOSS landing occured Jan.2025 and a second fire just occured Friday Sept.18th this month. Please see attachment BESS Moss Landing n...s ago. An explosion and fire occured at the Laverne Califonia BESS water treatment faciity just a day apart this month. The first fire and explosion Sept. 22nd 2026 and then the next day the batteries reheated triggering a complicated recooling process to prevent a thermal runaway. Please see attachment BESS LaVerne CA fir...t and BESS LaVerne CA Bes...t Residents had to remain evacuated for a second day. Normally evacuations are done prior to possible catastrophic events and however, is required immediately during BESS thermal runaways. I believe this newer technology is in it's beginning stages, and should be considered high industrial use and not located over residential auafers wetlands and wellheads such as my water supply that have 1,2,3, travel time zones and highly suceptable to contamination. The health risks can cause serious medical issues and even death depending on the failure of the mitigation. My property and home value would drop to the floor and would adversely create a major financial loss to the local public utility, because no one pays for contaminated water, and then comes the law suit that residents would have to use to hopefully reclaim any losses involving the home and property. Please see my attachment that indicates all the fires and failures from just one energy company. They are called TERRA-GEN energy company.! Please see attachment BESS Jillian Fried...May 2026.jpg. In conclusion the Draft Scoping in it's present form does not show accurate or up to date BESS risk assesement, is flawed and misleading as shown by the attachments submitted. In addition a Suffolk County lawsuit has been filed for current water contamination. To read the full article please use this link provided. https://www.newsday.com/long-island/politics/battery-storage-facility-east-hampton-water-contamination-gj45mx6g Thank you for your patience and understanding. Respectfully David Pedersen.↓
To the Department of Ecology, Clean Energy Coordination:
My name is Chandeshwar Mishra and I live at 36527 SE Woody Creek Ln. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale,...↓ lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the BESS Fisher Park project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Chandeshwar Mishra
36527 SE Woody Creek Ln↓
My name is Chandeshwar Mishra and I live at 36527 SE Woody Creek Ln. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale,...↓ lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed, the BESS Fisher Park project. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Chandeshwar Mishra
36527 SE Woody Creek Ln↓
No attachments
10/1/2026
To: Clean Energy Coordination, Washington State Department of Ecology
RE: Scoping Comments: Battery Energy Storage System Facilities Programmatic Environmental Impact Statement
Dear Clean Energy Coordination Team,
My name is Ariel Autum...↓n Castle, and I live on Snoqualmie Ridge in Snoqualmie, WA which resides in the Snoqualmie Valley. My home is near the proposed Cascadia Ridge battery energy storage facility, which its developer, Jupiter Power, has announced it will take to the Energy Facility Site Evaluation Council (EFSEC) for state certification.
I support Washington's clean energy goals and recognize that battery storage has an important role in the state's energy future. My concern is where and how these facilities are sited. Stand-alone BESS facilities are now being proposed next to dense neighborhoods, schools, parks, forests, and salmon-bearing waters. Because future project-level reviews will tier to this PEIS, its scope will shape whether communities like mine are protected.
I also ask Ecology to share the PEIS's findings with EFSEC and other lead agencies as the analysis is developed, rather than waiting for the final document in 2028. Projects such as Cascadia Ridge may move through review before the PEIS is complete. Those reviews should benefit from this work, and the PEIS's timeline should not leave a gap in which projects are approved without it.
I respectfully ask Ecology to include the following in the scope of the PEIS.
1. Public health: toxic plume exposure to residents, not only responders.
The scoping document frames hazardous emissions mainly as a risk to fire responders. For stand-alone BESS sited near dense neighborhoods, the greater exposure may fall on residents who have no training, protective equipment, or warning.
The PEIS should evaluate:
• Plume behavior and exposure radius. Model how toxic gases (hydrogen fluoride, hydrogen cyanide, carbon monoxide) and particulates travel downwind at increasing distances from the facility, such as 0.5, 1, 2, and 5 miles. Include worst-case conditions: nighttime temperature inversions that trap gases near the ground, valley and ridge terrain, and high winds. Isolation distances in current incident guidance are designed for responders at the scene, not for downwind neighborhoods, and should not be treated as a safe public setback.
• Exposure before warning or evacuation. Evaluate how much exposure could occur before an incident is detected, an alert is issued, and people can be notified and moved. This is especially important at night, when residents are asleep and least able to recognize or respond to a release. In a densely populated area, the time needed to alert and move thousands of people may exceed the time it takes a plume to reach them.
• Evacuation route capacity. Evaluate whether existing roads can move the full surrounding population out quickly, including school buses, people without vehicles, and people with medical needs or disabilities. Where they cannot, the PEIS should identify this as a siting constraint.
• Lasting harm to people and animals. Exposure to these gases can cause serious and permanent injury, including lasting lung damage, along with delayed-onset symptoms that may not appear for hours. Children, older adults, and people with respiratory conditions are especially vulnerable. The PEIS should also evaluate harm to pets, livestock, and wildlife, which cannot evacuate or be protected.
• Deposition and cleanup. Evaluate heavy metals and fluoride compounds settling on soil, vegetation, play areas, gardens, and homes, and set cleanup standards. Do not rely solely on air-monitoring conclusions from past incidents like Moss Landing. Include post-incident soil and sediment data.
• Medical capacity. Assess whether local hospitals can treat mass hydrogen fluoride exposure, including stocks of calcium gluconate antidote and decontamination capacity.
2. Siting criteria, exclusion areas, and setbacks.
Ecology's 2025 analysis of BESS paired with solar and wind assumed large facilities in remote areas, unlikely to be near cities. The scoping document acknowledges that stand-alone BESS are smaller and could be sited in a variety of locations. In practice, developers now propose them next to dense neighborhoods because they want quick connection to existing substations.
The PEIS's assumptions about suitable areas should reflect that reality.
I ask that the geographic scope go beyond proximity to infrastructure and also identify areas that are unsuitable for utility-scale BESS. These include:
• Residential neighborhoods, schools, parks, hospitals, and childcare facilities. Puget Sound Energy's own consultant-prepared siting study treats heavy residential presence, schools, and hospitals as indicators that a location is less desirable for energy storage.
• Wildland-urban interface zones and forested land, where a facility both adds an ignition source and is exposed to wildfire.
• Mapped and suspected fault zones, and areas with landslide, liquefaction, or steep-slope hazards.
• Critical areas: fish-bearing streams and their buffers, wetlands, floodplains, aquifer recharge areas, and areas with private domestic wells downgradient.
• Constrained valley and ridge terrain, where temperature inversions can trap emissions near the ground.
• Areas without municipal water service or fire hydrants, where firefighters would depend on tanker supply alone.
• Areas with limited evacuation routes relative to the surrounding population.
Setbacks. Washington has no statewide BESS setback requirements, and local standards vary widely. The PEIS should recommend minimum setback distances from homes, schools, parks, hospitals, and waterways, based on the plume modeling described in Section 1, not on equipment spacing or responder isolation distances. Setbacks should be measured from the nearest property line of the sensitive use, not from the nearest building.
Alternatives and site justification. The PEIS should recommend that project-level reviews require applicants to compare their chosen site with lower-impact alternatives that have similar grid access, such as previously disturbed, industrial, or brownfield land. Applicants should have to explain why a residential-adjacent or forested site was chosen over those options.
Preference for disturbed land. The PEIS should identify siting on previously cleared, industrial, or contaminated land as a primary way to avoid impacts. This avoids forest clearing, habitat loss, and new exposure for residential communities.
3. Wildlife, habitat, and forest loss.
Stand-alone BESS facilities are typically cleared of all vegetation, graveled, and fenced. Where they are sited on forested land, that clearing is permanent and irreversible.
The PEIS should evaluate:
• Loss of wildlife corridors. Forested parcels near developed areas often serve as the last connected movement routes for large mammals such as elk, black bear, cougar, bobcat, coyote, and deer. The PEIS should evaluate how clearing and fencing these parcels cuts off movement and pushes animals into neighborhoods and roadways, raising human–wildlife conflict and vehicle collisions.
• Habitat fragmentation, not just acres lost. A cleared, fenced site can split a larger habitat area into pieces too small to support some species.
• Wetlands. Wetlands filter pollutants, store floodwater, recharge groundwater, and provide breeding habitat for amphibians, birds, and insects. The PEIS should evaluate direct loss and indirect harm to wetlands near BESS sites from:
o Clearing within or near wetland buffers.
o Altered drainage that dries out or floods wetlands.
o Sediment from construction.
o Contaminated runoff during an incident.
A degraded wetland also loses its ability to protect downstream waters, which compounds every other water impact.
• Streams, rivers, and lakes as habitat. Forest cover keeps streams cool, shaded, and stable. The PEIS should evaluate how clearing and impervious surfaces near streams raise water temperatures, increase peak flows and bank erosion, and smother spawning gravels and insect habitat with sediment. Trout, salmon, amphibians, and the aquatic insects they feed on are all at risk. Lakes and ponds receiving runoff should be evaluated for sediment and contaminant buildup, which can persist for years.
• Riparian buffers. Recommend that project-level reviews apply current, not outdated, critical-area buffer standards. Some jurisdictions have recently widened stream buffers, especially where steep slopes are present.
• Construction-phase impacts. Assess disturbance to nesting birds and breeding or denning seasons, consistent with the Migratory Bird Treaty Act.
• Ongoing operational impacts. Assess 24/7 noise from cooling fans and inverters, security lighting at night, and fencing on nearby wildlife behavior.
• Toxic exposure to wildlife during an incident. Animals cannot be warned or evacuated. The PEIS should evaluate harm to wildlife, pets, livestock, fish, and amphibians from smoke, toxic gases, and contaminated water, sediment, or vegetation after a fire.
• Mitigation feasibility. Ecology's prior analysis acknowledged that mitigation for special-status habitats or species may not be feasible. The PEIS should treat avoidance as the primary mitigation: steer facilities away from intact forest, wetlands, stream corridors, and wildlife corridors, and toward previously disturbed land.
4. Water resources, salmon, orcas, and Tribal resources.
BESS facilities are often sited on hillsides or forested parcels above streams, wetlands, and rivers. Whatever leaves the site, in normal operation or during an incident, flows downhill into those waters and into groundwater.
The PEIS should evaluate:
• Fire suppression runoff. Battery fires can require very large volumes of cooling water over days. That water can carry heavy metals, fluoride compounds, electrolyte breakdown products, and firefighting chemicals, including PFAS-containing foams if used. The PEIS should evaluate where this water goes and how it can be fully contained, and should recommend containment capacity sized for a multi-day, full-facility event, not a single container.
• Stormwater and construction impacts. Clearing forest and adding impervious surface increases runoff volume, erosion, and sediment reaching streams, even without an incident. The PEIS should evaluate these impacts on steep or erosion-prone sites.
• Groundwater and drinking water. Contaminants can migrate through soil into aquifers. The PEIS should evaluate risks to private domestic wells and municipal wellfields downgradient of a facility. It should recommend that project-level reviews require a hydrogeologic assessment and baseline water-quality testing of nearby wells before construction.
• Salmon and Southern Resident orcas. Many proposed sites drain into rivers that support ESA-listed Chinook salmon, which are the primary food source for endangered Southern Resident orcas. A contamination event could harm salmon at multiple life stages and add stress to an already food-limited orca population. The PEIS should evaluate downstream impacts to listed fish, including contamination that reaches salmon habitat from sites upstream of natural barriers.
• Tribal rights and sacred waters. Rivers and waterways carry cultural, spiritual, and treaty-protected significance for Tribes. For example, the Snoqualmie Tribe has designated the Snoqualmie River and its tributaries a Cultural Waterway. The PEIS should treat contamination of such waters as a potentially significant, unavoidable impact, and should evaluate it through consultation with affected Tribes.
• Monitoring and cleanup. The PEIS should recommend ongoing water-quality monitoring for operating facilities. It should also set clear cleanup standards, timelines, and financial responsibility for any contamination of surface water, groundwater, or sediment.
5. Wildfire.
Ecology's prior analysis described wildfire risk from BESS mainly as a new ignition source in remote locations with limited response. Stand-alone facilities in wildland-urban interface (WUI) areas present a different and more serious risk, because forest, homes, and the facility sit side by side.
The PEIS should evaluate:
• Risk in both directions. A battery fire can throw embers and radiant heat into surrounding forest and start a wildfire. A wildfire can also reach a facility and trigger thermal runaway in multiple containers at once. That would create a combined wildfire and toxic-chemical event that is far harder to fight and evacuate from than either alone.
• Wind-driven fire spread. Evaluate how seasonal high winds and windstorms could spread a battery fire's embers, smoke, and toxic plume quickly into nearby neighborhoods and forest. This includes wind events outside the traditional summer fire season.
• Changing fire conditions. Western Washington's fire risk is increasing with hotter, drier summers. The PEIS should use forward-looking climate projections, not historical fire records alone, when evaluating wildfire risk over a facility's 20-plus-year life.
• Firefighting limits. Evaluate whether local fire agencies can fight a battery fire and a spreading wildfire at the same time, especially where there is no municipal water supply or hydrants and where mutual-aid resources may already be committed during regional fire events.
• Smoke combined with toxic emissions. Evaluate health impacts when wildfire smoke and battery fire emissions mix, particularly for children, older adults, and people with respiratory conditions.
• Evacuation during wildfire. Evaluate whether evacuation routes could be blocked or overwhelmed by fire, smoke, or heavy traffic at the same moment residents need to leave.
• Reignition. Battery fires can reignite days or weeks after appearing to be out. Evaluate the extended wildfire risk this creates for surrounding forest.
• Mitigation and siting. Recommend defensible space and vegetation management standards, fire-resistant site design, and on-site water supply requirements. The PEIS should also identify WUI and forested areas as poor locations for BESS, treating avoidance as the primary mitigation.
6. Seismic hazard.
Western Washington faces both a Cascadia Subduction Zone megathrust earthquake and shallow crustal fault earthquakes, such as on the Seattle Fault and the Southern Whidbey Island Fault Zone. USGS estimates a high probability of a damaging earthquake in the Puget Sound region within the next 50 years. The scoping document does not name seismic risk. I ask that it be explicitly included under Earth Resources and Environmental Health and Safety.
The PEIS should evaluate:
• Earthquake-triggered thermal runaway. Current seismic standards for electrical equipment mainly ensure that equipment stays anchored and upright. They do not show whether battery cells can survive strong or prolonged shaking without internal damage that leads to overheating and fire, sometimes hours or days later. There is little real-world data on how large BESS facilities perform in major earthquakes.
• Multiple simultaneous failures. A single earthquake could damage many containers at once, overwhelming fire suppression systems designed for a single-container event.
• Ground failure. Evaluate liquefaction, landslides, and slope failure, especially for facilities on hillsides, steep slopes, or fill. Ground movement could break containment, foundations, or spill-control systems.
• The full chain of impacts. Model the sequence from earthquake to battery damage, fire, toxic release, and contaminated runoff into streams and groundwater, rather than evaluating each hazard separately.
• Emergency response after an earthquake. After a major quake, fire agencies will be stretched across the region. Roads and bridges may be damaged, water systems may fail, and communication may be disrupted. A BESS fire in that setting could burn with little or no response while residents are unable to evacuate.
• Aftershocks. Evaluate risks to damaged facilities and to responders during aftershocks.
• Siting and design. Recommend site-specific geotechnical and fault studies for every project. Seismic design standards should address battery cell integrity, not just equipment anchoring. The PEIS should identify areas near active faults, or with high liquefaction or landslide risk, as poor locations for BESS.
7. Emergency response, readiness, and evacuation planning.
Section 1 addresses evacuation route capacity. This section addresses whether the agencies responsible for public safety are equipped to respond at all.
The PEIS should evaluate:
• Local fire agency readiness. Battery fires differ from structure fires. They produce explosive and toxic gases, resist water, can reignite for days or weeks, and require specialized monitoring equipment and training. Many local agencies are not equipped for them. For example, Eastside Fire & Rescue has stated in writing that it "cannot confirm that we are fully prepared today to mitigate an incident of this type and scale." King County Fire District 38, which has jurisdiction over the proposed Cascadia Ridge site, has formally opposed the siting and stated that local resources are not adequate for a BESS emergency. The PEIS should recommend that demonstrated local readiness be a condition of approval, not an assumption.
• Firefighting water supply. Evaluate sites without municipal water or hydrants, where responders depend on tanker trucks alone during a multi-day event.
• Mutual aid capacity. Evaluate whether regional mutual aid can sustain a multi-day battery fire, especially when resources are already committed to wildfires, storms, or earthquakes.
• Public alerts and notification. Evaluate how quickly residents, schools, and businesses can be warned of a toxic release, including at night, and whether alert systems reach everyone, including people who don't speak English and people with disabilities. Recommend real-time air monitoring at facility boundaries, linked to automatic public alerts.
• Schools, childcare, and vulnerable populations. Evaluate shelter-in-place, evacuation, and family reunification plans for nearby schools, as well as plans for medically fragile residents, care facilities, and people without vehicles.
• Hospital and medical capacity. Evaluate whether local hospitals can treat mass toxic gas exposure (see Section 1).
• Emergency plans before approval. Recommend that site-specific emergency response plans, evacuation plans, and toxic-release scenarios be completed, shared with local agencies, and made public before a project is approved, not deferred to after permitting.
• Responder safety. Evaluate protective equipment, gas monitoring, and training needs for responders, including volunteer and rural departments.
8. Safety codes, battery chemistry, and financial responsibility.
Outdated codes. The scoping document acknowledges that Washington has not adopted the most recent edition of NFPA 855 (2026), and that state code references earlier editions of UL 9540A than the current one. Projects permitted under older standards may operate for 20 years or more without the benefit of current safety knowledge.
The PEIS should:
• Recommend that all new projects meet the most current editions of NFPA 855, UL 9540, and UL 9540A, regardless of what state code has adopted.
• Recommend that the state adopt these updates promptly.
• Recommend that projects stay current with safety upgrades over their operating life, not only at the time of permitting.
Battery chemistry. The PEIS is limited to lithium-ion batteries. However, lithium-ion chemistries differ significantly in fire behavior and toxic emissions, and safer alternatives are emerging. The PEIS should:
• Evaluate impacts separately by chemistry, such as lithium iron phosphate (LFP) and nickel manganese cobalt (NMC), rather than treating all lithium-ion as one category.
• Evaluate lower-risk chemistries as mitigation, including sodium-ion and other non-lithium technologies, especially for sites near homes, schools, and sensitive environments.
• Require chemistry disclosure and commitment before environmental review. Developers should not be allowed to complete environmental review with the chemistry "not yet selected," or to substitute "similar technology" after approval without new review.
• Require public release of large-scale fire test results (UL 9540A) for the specific product proposed, and an independent third-party safety review before approval.
Financial responsibility. Large BESS fires have produced cleanup, response, and remediation costs far exceeding typical bond amounts. For example, King County's current ordinance caps financial responsibility at $1 million. The PEIS should recommend:
• Financial assurance scaled to the worst-case cost of fire response, environmental cleanup, and long-term monitoring, rather than a flat cap.
• Separate decommissioning bonds covering battery removal, recycling, and site restoration.
• Clear liability for harm to public health, private property, wells, and natural resources, with a defined process for affected residents to be compensated.
• Requirements that financial assurance remain in place, and transfer intact, if the facility is sold or the owner goes bankrupt.
End of life. Evaluate battery replacement (augmentation), recycling, disposal of hazardous materials, and full site restoration at decommissioning, including restoring forest and habitat where land was cleared.
9. Cumulative impacts and project scale.
Full buildout, not just phase one. Developers may present a smaller initial capacity to the public while designing sites for much larger future expansion. For example, publicly released civil plans for the proposed Cascadia Ridge facility point to a 410 MW / 1,640 MWh buildout, compared to the 130 MW figure presented to the public. The PEIS should recommend that project-level reviews evaluate the maximum capacity a site is designed or permitted to hold, including future phases, battery augmentation, and expansion. Later expansions should not be allowed without new environmental review.
Clustering around substations. Developers often seek sites near the same substations and transmission lines. The PEIS should evaluate the cumulative effect of multiple BESS facilities, substations, and transmission lines concentrated in one community. This includes combined fire and toxic-release risk, noise, visual impact, habitat loss, and emergency response demand.
BESS serving large new loads. The PEIS should also evaluate BESS facilities built to serve or support large new loads such as data centers, including the cumulative impacts when both are sited in or near the same community.
Combined hazard events. Evaluate how BESS risk compounds with other hazards a community already faces, such as wildfire, windstorms, flooding, and earthquakes, which may occur at the same time and strain the same response resources.
Regional habitat and forest loss. Evaluate the cumulative loss of forest, wildlife corridors, and wetlands as multiple facilities are built across a region, not just the acres lost at each individual site.
Cumulative burden on communities. Evaluate whether certain communities are being asked to host a disproportionate share of energy infrastructure risk while the benefits flow to the broader regional grid and to private investors. This connects to the PEIS's environmental justice analysis.
Watershed-scale impacts. Evaluate cumulative effects on a watershed when multiple facilities, construction projects, and impervious surfaces drain into the same streams, wetlands, and salmon-bearing rivers.
Closing.
I want to be direct about what is at stake for families like mine. We moved to Snoqualmie Ridge in 2018 and intended to stay for the rest of our lives. We love this valley: its forests, rivers, trails, wildlife, and community. My teenager attends Mt. Si High School, about a mile from the proposed facility.
I am deeply concerned for my family's health and safety. If the Cascadia Ridge facility is approved at this location, we will sell our home and leave the community we love rather than live with these risks. Many of my neighbors have told me the same. When a single facility can push long-time residents out of their homes, the siting process has failed to account for its true impacts.
I am a strong supporter of clean energy and of Washington's climate goals. I understand that a growing population, electrification, and new large energy users are putting real pressure on the grid, and that storage is part of the solution. But there are many ways to meet that need without placing clear and avoidable risks on families and communities. These include energy efficiency and demand response, distributed storage paired with rooftop solar, and siting utility-scale facilities on industrial, previously disturbed, or remote land with safe separation from homes and schools. This is not opposition to clean energy. It is a request that Washington get siting right. This PEIS is an opportunity to set that standard for the entire state. I urge Ecology to use it fully, and to build a scope that reflects how and where these facilities are actually being proposed today.
Thank you for your time and for the opportunity to comment. I look forward to reviewing the Draft PEIS.
Respectfully,
Ariel Autumn Castle
34405 SE Cochrane Street
Snoqualmie, WA 98065
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To: Clean Energy Coordination, Washington State Department of Ecology
RE: Scoping Comments: Battery Energy Storage System Facilities Programmatic Environmental Impact Statement
Dear Clean Energy Coordination Team,
My name is Ariel Autum...↓n Castle, and I live on Snoqualmie Ridge in Snoqualmie, WA which resides in the Snoqualmie Valley. My home is near the proposed Cascadia Ridge battery energy storage facility, which its developer, Jupiter Power, has announced it will take to the Energy Facility Site Evaluation Council (EFSEC) for state certification.
I support Washington's clean energy goals and recognize that battery storage has an important role in the state's energy future. My concern is where and how these facilities are sited. Stand-alone BESS facilities are now being proposed next to dense neighborhoods, schools, parks, forests, and salmon-bearing waters. Because future project-level reviews will tier to this PEIS, its scope will shape whether communities like mine are protected.
I also ask Ecology to share the PEIS's findings with EFSEC and other lead agencies as the analysis is developed, rather than waiting for the final document in 2028. Projects such as Cascadia Ridge may move through review before the PEIS is complete. Those reviews should benefit from this work, and the PEIS's timeline should not leave a gap in which projects are approved without it.
I respectfully ask Ecology to include the following in the scope of the PEIS.
1. Public health: toxic plume exposure to residents, not only responders.
The scoping document frames hazardous emissions mainly as a risk to fire responders. For stand-alone BESS sited near dense neighborhoods, the greater exposure may fall on residents who have no training, protective equipment, or warning.
The PEIS should evaluate:
• Plume behavior and exposure radius. Model how toxic gases (hydrogen fluoride, hydrogen cyanide, carbon monoxide) and particulates travel downwind at increasing distances from the facility, such as 0.5, 1, 2, and 5 miles. Include worst-case conditions: nighttime temperature inversions that trap gases near the ground, valley and ridge terrain, and high winds. Isolation distances in current incident guidance are designed for responders at the scene, not for downwind neighborhoods, and should not be treated as a safe public setback.
• Exposure before warning or evacuation. Evaluate how much exposure could occur before an incident is detected, an alert is issued, and people can be notified and moved. This is especially important at night, when residents are asleep and least able to recognize or respond to a release. In a densely populated area, the time needed to alert and move thousands of people may exceed the time it takes a plume to reach them.
• Evacuation route capacity. Evaluate whether existing roads can move the full surrounding population out quickly, including school buses, people without vehicles, and people with medical needs or disabilities. Where they cannot, the PEIS should identify this as a siting constraint.
• Lasting harm to people and animals. Exposure to these gases can cause serious and permanent injury, including lasting lung damage, along with delayed-onset symptoms that may not appear for hours. Children, older adults, and people with respiratory conditions are especially vulnerable. The PEIS should also evaluate harm to pets, livestock, and wildlife, which cannot evacuate or be protected.
• Deposition and cleanup. Evaluate heavy metals and fluoride compounds settling on soil, vegetation, play areas, gardens, and homes, and set cleanup standards. Do not rely solely on air-monitoring conclusions from past incidents like Moss Landing. Include post-incident soil and sediment data.
• Medical capacity. Assess whether local hospitals can treat mass hydrogen fluoride exposure, including stocks of calcium gluconate antidote and decontamination capacity.
2. Siting criteria, exclusion areas, and setbacks.
Ecology's 2025 analysis of BESS paired with solar and wind assumed large facilities in remote areas, unlikely to be near cities. The scoping document acknowledges that stand-alone BESS are smaller and could be sited in a variety of locations. In practice, developers now propose them next to dense neighborhoods because they want quick connection to existing substations.
The PEIS's assumptions about suitable areas should reflect that reality.
I ask that the geographic scope go beyond proximity to infrastructure and also identify areas that are unsuitable for utility-scale BESS. These include:
• Residential neighborhoods, schools, parks, hospitals, and childcare facilities. Puget Sound Energy's own consultant-prepared siting study treats heavy residential presence, schools, and hospitals as indicators that a location is less desirable for energy storage.
• Wildland-urban interface zones and forested land, where a facility both adds an ignition source and is exposed to wildfire.
• Mapped and suspected fault zones, and areas with landslide, liquefaction, or steep-slope hazards.
• Critical areas: fish-bearing streams and their buffers, wetlands, floodplains, aquifer recharge areas, and areas with private domestic wells downgradient.
• Constrained valley and ridge terrain, where temperature inversions can trap emissions near the ground.
• Areas without municipal water service or fire hydrants, where firefighters would depend on tanker supply alone.
• Areas with limited evacuation routes relative to the surrounding population.
Setbacks. Washington has no statewide BESS setback requirements, and local standards vary widely. The PEIS should recommend minimum setback distances from homes, schools, parks, hospitals, and waterways, based on the plume modeling described in Section 1, not on equipment spacing or responder isolation distances. Setbacks should be measured from the nearest property line of the sensitive use, not from the nearest building.
Alternatives and site justification. The PEIS should recommend that project-level reviews require applicants to compare their chosen site with lower-impact alternatives that have similar grid access, such as previously disturbed, industrial, or brownfield land. Applicants should have to explain why a residential-adjacent or forested site was chosen over those options.
Preference for disturbed land. The PEIS should identify siting on previously cleared, industrial, or contaminated land as a primary way to avoid impacts. This avoids forest clearing, habitat loss, and new exposure for residential communities.
3. Wildlife, habitat, and forest loss.
Stand-alone BESS facilities are typically cleared of all vegetation, graveled, and fenced. Where they are sited on forested land, that clearing is permanent and irreversible.
The PEIS should evaluate:
• Loss of wildlife corridors. Forested parcels near developed areas often serve as the last connected movement routes for large mammals such as elk, black bear, cougar, bobcat, coyote, and deer. The PEIS should evaluate how clearing and fencing these parcels cuts off movement and pushes animals into neighborhoods and roadways, raising human–wildlife conflict and vehicle collisions.
• Habitat fragmentation, not just acres lost. A cleared, fenced site can split a larger habitat area into pieces too small to support some species.
• Wetlands. Wetlands filter pollutants, store floodwater, recharge groundwater, and provide breeding habitat for amphibians, birds, and insects. The PEIS should evaluate direct loss and indirect harm to wetlands near BESS sites from:
o Clearing within or near wetland buffers.
o Altered drainage that dries out or floods wetlands.
o Sediment from construction.
o Contaminated runoff during an incident.
A degraded wetland also loses its ability to protect downstream waters, which compounds every other water impact.
• Streams, rivers, and lakes as habitat. Forest cover keeps streams cool, shaded, and stable. The PEIS should evaluate how clearing and impervious surfaces near streams raise water temperatures, increase peak flows and bank erosion, and smother spawning gravels and insect habitat with sediment. Trout, salmon, amphibians, and the aquatic insects they feed on are all at risk. Lakes and ponds receiving runoff should be evaluated for sediment and contaminant buildup, which can persist for years.
• Riparian buffers. Recommend that project-level reviews apply current, not outdated, critical-area buffer standards. Some jurisdictions have recently widened stream buffers, especially where steep slopes are present.
• Construction-phase impacts. Assess disturbance to nesting birds and breeding or denning seasons, consistent with the Migratory Bird Treaty Act.
• Ongoing operational impacts. Assess 24/7 noise from cooling fans and inverters, security lighting at night, and fencing on nearby wildlife behavior.
• Toxic exposure to wildlife during an incident. Animals cannot be warned or evacuated. The PEIS should evaluate harm to wildlife, pets, livestock, fish, and amphibians from smoke, toxic gases, and contaminated water, sediment, or vegetation after a fire.
• Mitigation feasibility. Ecology's prior analysis acknowledged that mitigation for special-status habitats or species may not be feasible. The PEIS should treat avoidance as the primary mitigation: steer facilities away from intact forest, wetlands, stream corridors, and wildlife corridors, and toward previously disturbed land.
4. Water resources, salmon, orcas, and Tribal resources.
BESS facilities are often sited on hillsides or forested parcels above streams, wetlands, and rivers. Whatever leaves the site, in normal operation or during an incident, flows downhill into those waters and into groundwater.
The PEIS should evaluate:
• Fire suppression runoff. Battery fires can require very large volumes of cooling water over days. That water can carry heavy metals, fluoride compounds, electrolyte breakdown products, and firefighting chemicals, including PFAS-containing foams if used. The PEIS should evaluate where this water goes and how it can be fully contained, and should recommend containment capacity sized for a multi-day, full-facility event, not a single container.
• Stormwater and construction impacts. Clearing forest and adding impervious surface increases runoff volume, erosion, and sediment reaching streams, even without an incident. The PEIS should evaluate these impacts on steep or erosion-prone sites.
• Groundwater and drinking water. Contaminants can migrate through soil into aquifers. The PEIS should evaluate risks to private domestic wells and municipal wellfields downgradient of a facility. It should recommend that project-level reviews require a hydrogeologic assessment and baseline water-quality testing of nearby wells before construction.
• Salmon and Southern Resident orcas. Many proposed sites drain into rivers that support ESA-listed Chinook salmon, which are the primary food source for endangered Southern Resident orcas. A contamination event could harm salmon at multiple life stages and add stress to an already food-limited orca population. The PEIS should evaluate downstream impacts to listed fish, including contamination that reaches salmon habitat from sites upstream of natural barriers.
• Tribal rights and sacred waters. Rivers and waterways carry cultural, spiritual, and treaty-protected significance for Tribes. For example, the Snoqualmie Tribe has designated the Snoqualmie River and its tributaries a Cultural Waterway. The PEIS should treat contamination of such waters as a potentially significant, unavoidable impact, and should evaluate it through consultation with affected Tribes.
• Monitoring and cleanup. The PEIS should recommend ongoing water-quality monitoring for operating facilities. It should also set clear cleanup standards, timelines, and financial responsibility for any contamination of surface water, groundwater, or sediment.
5. Wildfire.
Ecology's prior analysis described wildfire risk from BESS mainly as a new ignition source in remote locations with limited response. Stand-alone facilities in wildland-urban interface (WUI) areas present a different and more serious risk, because forest, homes, and the facility sit side by side.
The PEIS should evaluate:
• Risk in both directions. A battery fire can throw embers and radiant heat into surrounding forest and start a wildfire. A wildfire can also reach a facility and trigger thermal runaway in multiple containers at once. That would create a combined wildfire and toxic-chemical event that is far harder to fight and evacuate from than either alone.
• Wind-driven fire spread. Evaluate how seasonal high winds and windstorms could spread a battery fire's embers, smoke, and toxic plume quickly into nearby neighborhoods and forest. This includes wind events outside the traditional summer fire season.
• Changing fire conditions. Western Washington's fire risk is increasing with hotter, drier summers. The PEIS should use forward-looking climate projections, not historical fire records alone, when evaluating wildfire risk over a facility's 20-plus-year life.
• Firefighting limits. Evaluate whether local fire agencies can fight a battery fire and a spreading wildfire at the same time, especially where there is no municipal water supply or hydrants and where mutual-aid resources may already be committed during regional fire events.
• Smoke combined with toxic emissions. Evaluate health impacts when wildfire smoke and battery fire emissions mix, particularly for children, older adults, and people with respiratory conditions.
• Evacuation during wildfire. Evaluate whether evacuation routes could be blocked or overwhelmed by fire, smoke, or heavy traffic at the same moment residents need to leave.
• Reignition. Battery fires can reignite days or weeks after appearing to be out. Evaluate the extended wildfire risk this creates for surrounding forest.
• Mitigation and siting. Recommend defensible space and vegetation management standards, fire-resistant site design, and on-site water supply requirements. The PEIS should also identify WUI and forested areas as poor locations for BESS, treating avoidance as the primary mitigation.
6. Seismic hazard.
Western Washington faces both a Cascadia Subduction Zone megathrust earthquake and shallow crustal fault earthquakes, such as on the Seattle Fault and the Southern Whidbey Island Fault Zone. USGS estimates a high probability of a damaging earthquake in the Puget Sound region within the next 50 years. The scoping document does not name seismic risk. I ask that it be explicitly included under Earth Resources and Environmental Health and Safety.
The PEIS should evaluate:
• Earthquake-triggered thermal runaway. Current seismic standards for electrical equipment mainly ensure that equipment stays anchored and upright. They do not show whether battery cells can survive strong or prolonged shaking without internal damage that leads to overheating and fire, sometimes hours or days later. There is little real-world data on how large BESS facilities perform in major earthquakes.
• Multiple simultaneous failures. A single earthquake could damage many containers at once, overwhelming fire suppression systems designed for a single-container event.
• Ground failure. Evaluate liquefaction, landslides, and slope failure, especially for facilities on hillsides, steep slopes, or fill. Ground movement could break containment, foundations, or spill-control systems.
• The full chain of impacts. Model the sequence from earthquake to battery damage, fire, toxic release, and contaminated runoff into streams and groundwater, rather than evaluating each hazard separately.
• Emergency response after an earthquake. After a major quake, fire agencies will be stretched across the region. Roads and bridges may be damaged, water systems may fail, and communication may be disrupted. A BESS fire in that setting could burn with little or no response while residents are unable to evacuate.
• Aftershocks. Evaluate risks to damaged facilities and to responders during aftershocks.
• Siting and design. Recommend site-specific geotechnical and fault studies for every project. Seismic design standards should address battery cell integrity, not just equipment anchoring. The PEIS should identify areas near active faults, or with high liquefaction or landslide risk, as poor locations for BESS.
7. Emergency response, readiness, and evacuation planning.
Section 1 addresses evacuation route capacity. This section addresses whether the agencies responsible for public safety are equipped to respond at all.
The PEIS should evaluate:
• Local fire agency readiness. Battery fires differ from structure fires. They produce explosive and toxic gases, resist water, can reignite for days or weeks, and require specialized monitoring equipment and training. Many local agencies are not equipped for them. For example, Eastside Fire & Rescue has stated in writing that it "cannot confirm that we are fully prepared today to mitigate an incident of this type and scale." King County Fire District 38, which has jurisdiction over the proposed Cascadia Ridge site, has formally opposed the siting and stated that local resources are not adequate for a BESS emergency. The PEIS should recommend that demonstrated local readiness be a condition of approval, not an assumption.
• Firefighting water supply. Evaluate sites without municipal water or hydrants, where responders depend on tanker trucks alone during a multi-day event.
• Mutual aid capacity. Evaluate whether regional mutual aid can sustain a multi-day battery fire, especially when resources are already committed to wildfires, storms, or earthquakes.
• Public alerts and notification. Evaluate how quickly residents, schools, and businesses can be warned of a toxic release, including at night, and whether alert systems reach everyone, including people who don't speak English and people with disabilities. Recommend real-time air monitoring at facility boundaries, linked to automatic public alerts.
• Schools, childcare, and vulnerable populations. Evaluate shelter-in-place, evacuation, and family reunification plans for nearby schools, as well as plans for medically fragile residents, care facilities, and people without vehicles.
• Hospital and medical capacity. Evaluate whether local hospitals can treat mass toxic gas exposure (see Section 1).
• Emergency plans before approval. Recommend that site-specific emergency response plans, evacuation plans, and toxic-release scenarios be completed, shared with local agencies, and made public before a project is approved, not deferred to after permitting.
• Responder safety. Evaluate protective equipment, gas monitoring, and training needs for responders, including volunteer and rural departments.
8. Safety codes, battery chemistry, and financial responsibility.
Outdated codes. The scoping document acknowledges that Washington has not adopted the most recent edition of NFPA 855 (2026), and that state code references earlier editions of UL 9540A than the current one. Projects permitted under older standards may operate for 20 years or more without the benefit of current safety knowledge.
The PEIS should:
• Recommend that all new projects meet the most current editions of NFPA 855, UL 9540, and UL 9540A, regardless of what state code has adopted.
• Recommend that the state adopt these updates promptly.
• Recommend that projects stay current with safety upgrades over their operating life, not only at the time of permitting.
Battery chemistry. The PEIS is limited to lithium-ion batteries. However, lithium-ion chemistries differ significantly in fire behavior and toxic emissions, and safer alternatives are emerging. The PEIS should:
• Evaluate impacts separately by chemistry, such as lithium iron phosphate (LFP) and nickel manganese cobalt (NMC), rather than treating all lithium-ion as one category.
• Evaluate lower-risk chemistries as mitigation, including sodium-ion and other non-lithium technologies, especially for sites near homes, schools, and sensitive environments.
• Require chemistry disclosure and commitment before environmental review. Developers should not be allowed to complete environmental review with the chemistry "not yet selected," or to substitute "similar technology" after approval without new review.
• Require public release of large-scale fire test results (UL 9540A) for the specific product proposed, and an independent third-party safety review before approval.
Financial responsibility. Large BESS fires have produced cleanup, response, and remediation costs far exceeding typical bond amounts. For example, King County's current ordinance caps financial responsibility at $1 million. The PEIS should recommend:
• Financial assurance scaled to the worst-case cost of fire response, environmental cleanup, and long-term monitoring, rather than a flat cap.
• Separate decommissioning bonds covering battery removal, recycling, and site restoration.
• Clear liability for harm to public health, private property, wells, and natural resources, with a defined process for affected residents to be compensated.
• Requirements that financial assurance remain in place, and transfer intact, if the facility is sold or the owner goes bankrupt.
End of life. Evaluate battery replacement (augmentation), recycling, disposal of hazardous materials, and full site restoration at decommissioning, including restoring forest and habitat where land was cleared.
9. Cumulative impacts and project scale.
Full buildout, not just phase one. Developers may present a smaller initial capacity to the public while designing sites for much larger future expansion. For example, publicly released civil plans for the proposed Cascadia Ridge facility point to a 410 MW / 1,640 MWh buildout, compared to the 130 MW figure presented to the public. The PEIS should recommend that project-level reviews evaluate the maximum capacity a site is designed or permitted to hold, including future phases, battery augmentation, and expansion. Later expansions should not be allowed without new environmental review.
Clustering around substations. Developers often seek sites near the same substations and transmission lines. The PEIS should evaluate the cumulative effect of multiple BESS facilities, substations, and transmission lines concentrated in one community. This includes combined fire and toxic-release risk, noise, visual impact, habitat loss, and emergency response demand.
BESS serving large new loads. The PEIS should also evaluate BESS facilities built to serve or support large new loads such as data centers, including the cumulative impacts when both are sited in or near the same community.
Combined hazard events. Evaluate how BESS risk compounds with other hazards a community already faces, such as wildfire, windstorms, flooding, and earthquakes, which may occur at the same time and strain the same response resources.
Regional habitat and forest loss. Evaluate the cumulative loss of forest, wildlife corridors, and wetlands as multiple facilities are built across a region, not just the acres lost at each individual site.
Cumulative burden on communities. Evaluate whether certain communities are being asked to host a disproportionate share of energy infrastructure risk while the benefits flow to the broader regional grid and to private investors. This connects to the PEIS's environmental justice analysis.
Watershed-scale impacts. Evaluate cumulative effects on a watershed when multiple facilities, construction projects, and impervious surfaces drain into the same streams, wetlands, and salmon-bearing rivers.
Closing.
I want to be direct about what is at stake for families like mine. We moved to Snoqualmie Ridge in 2018 and intended to stay for the rest of our lives. We love this valley: its forests, rivers, trails, wildlife, and community. My teenager attends Mt. Si High School, about a mile from the proposed facility.
I am deeply concerned for my family's health and safety. If the Cascadia Ridge facility is approved at this location, we will sell our home and leave the community we love rather than live with these risks. Many of my neighbors have told me the same. When a single facility can push long-time residents out of their homes, the siting process has failed to account for its true impacts.
I am a strong supporter of clean energy and of Washington's climate goals. I understand that a growing population, electrification, and new large energy users are putting real pressure on the grid, and that storage is part of the solution. But there are many ways to meet that need without placing clear and avoidable risks on families and communities. These include energy efficiency and demand response, distributed storage paired with rooftop solar, and siting utility-scale facilities on industrial, previously disturbed, or remote land with safe separation from homes and schools. This is not opposition to clean energy. It is a request that Washington get siting right. This PEIS is an opportunity to set that standard for the entire state. I urge Ecology to use it fully, and to build a scope that reflects how and where these facilities are actually being proposed today.
Thank you for your time and for the opportunity to comment. I look forward to reviewing the Draft PEIS.
Respectfully,
Ariel Autumn Castle
34405 SE Cochrane Street
Snoqualmie, WA 98065
↓
Attachments:
The Washington Public Utility Districts Association (WPUDA) represents 27 public utility districts providing essential, not-for-profit energy, water and wastewater services across Washington.
We appreciate the opportunity to comment on the scoping ...↓for the Programmatic Environmental Impact Statement for Battery Energy Storage Systems in Washington state.
Policy Context
The development of Battery Energy Storage Systems (BESS) is essential to meeting the statutory mandates of the Clean Energy Transformation Act (CETA) and the Climate Commitment Act (CCA), which require Washington to achieve a 100% renewable or zero-carbon electrical grid by 2045 and net-zero greenhouse gas emissions by 2050. As state energy demand is projected to more than double by 2050, BESS facilities may provide the necessary grid stabilization to integrate intermittent clean energy sources, such as wind and solar, by storing surplus power for release during peak demand periods.
Siting and Land Use Consistency Recommendations
The PEIS should include a comprehensive analysis of siting stand-alone BESS facilities in a manner consistent and commensurate with light industrial uses, specifically retail distribution centers or big-box warehouses. Factual considerations for this recommendation include:
Physical Footprint: Utility-scale BESS are often housed within "warehouse-type" enclosures or standardized 40-foot shipping containers (approximately 8 feet wide and 8.5 feet tall) installed on concrete foundations.
Infrastructure Requirements: These facilities utilize standard industrial components, including heating, ventilation, and air conditioning (HVAC) units, auxiliary electrical systems, and graveled, fenced perimeters.
Siting Versatility: Unlike co-located BESS that cover large areas far from urban centers, stand-alone facilities are smaller in scale and can be sited in diverse locations, including areas in or near cities where electricity demand is highest.
Environmental Health and Safety Risks
While BESS is critical for the "green transformation," the PEIS must provide a rigorous evaluation of the risks associated with thermal runaway events. Research indicates that battery failures can lead to the leakage of electrolytes or ignition, releasing toxic gases that cause irritation to the skin and lungs.
The PEIS should specifically reference the 2025 Moss Landing incident in California, where a battery fire necessitated the 24-hour evacuation of approximately 1,200 residents.
Evaluation must be conducted on the potential for:
Significant environmental harm to local water resources and fish populations from fire suppression runoff or chemical leaks.
Impacts on public services, particularly the burden on local fire departments in remote locations with limited response capabilities for specialized lithium-ion fires.
Regulatory Alignment and Mitigation
Consistency with existing statute is essential when developing the PEIS. Current statute directs state agencies under RCW 43.21C.030 (b) Identify and develop methods and procedures, in consultation with the department of ecology and the ecological commission, which will ensure that presently unquantified environmental amenities and values will be given appropriate consideration in decision making along with economic and technical considerations;
As such, the economic and technical burden of these facilities must be fully evaluated, understood, and accounted for to ensure alignment with statutory requirements.
As of August 2026, Washington state has not yet adopted the most recent safety standards, such as the 2026 version of NFPA 855 or the latest UL 9540A performance testing standards. The PEIS should identify these regulatory gaps and recommend that project-level reviews utilize the most current national safety codes to establish adequate separation distances and fire suppression protocols.
In conclusion, the PEIS should provide a framework that facilitates the rapid deployment of BESS to support intermittent energy resources while establishing stringent siting and safety requirements to prevent the catastrophic environmental and public health outcomes associated with battery failure incidents.
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No attachments
My name is Vasileios Zois, and I am a resident of Snoqualmie, Washington. I am submitting this scoping comment regarding the Programmatic Environmental Impact Statement (PEIS) for stand-alone, utility-scale, lithium-ion battery energy storage system ...↓(BESS) facilities in Washington State (Publication No. 26-06-017).
This PEIS directly impacts my family and community. A stand-alone utility-scale BESS facility is currently proposed in the Snoqualmie Valley, in close proximity to residential neighborhoods and Quantum STEM School, which my child attends. Furthermore, our community relies on single-access transit corridors—including SR 202, SR 18, and I-90—which serve as vital daily transit and sole emergency evacuation routes for valley residents.
Because Ecology has explicitly stated that future project-level SEPA reviews will tier to this PEIS, and because stand-alone facilities are increasingly being proposed near populated suburban communities rather than remote industrial zones, this PEIS must evaluate real-world siting conditions. I request that Ecology incorporate the following key parameters into the PEIS scope:
Key Scoping Requests
Q1 · Facility Types & Baseline Standards
The PEIS must evaluate the full operational spectrum of stand-alone, containerized lithium-ion BESS installations as they are actually being proposed in Washington State, specifically those sited near residential neighborhoods, schools, and constrained transportation corridors.
Code Baseline vs. Modern Standards: The PEIS should explicitly model risks based on the building and fire codes Washington has currently adopted, while evaluating updated safety standards—such as the most recent edition of NFPA 855 and full-scale UL 9540A fire testing—as essential, mandatory mitigation measures rather than optional upgrades.
Independent Failure Data: Safety, failure-rate, and thermal runaway analyses must rely on independent, peer-reviewed safety data rather than self-reported or industry-funded research data.
Expanded Definition of Harm: The study must define offsite impacts to include mandatory evacuations, shelter-in-place orders, prolonged community displacement, and hazardous waste remediation—not just direct fire or structural damage.
Q2 · Geographic Scope & Site-Suitability Screening
Suitability must be defined by public health, safety, and environmental protection—not merely electrical grid proximity or land availability.
Exclusionary Screening Criteria: The PEIS geographic scope should establish clear environmental and safety screening thresholds. Siting assumptions must explicitly account for and screen out:
Proximity to high-density residential areas, schools, child-care facilities, and medical centers.
Areas dependent on private drinking-water wells or located within critical aquifer recharge areas.
100-year floodplains, liquefaction zones, and mapped seismic fault lines.
Wildland-Urban Interface (WUI) and fire-prone zones.
Communities with constrained egress or single-road evacuation bottlenecks (such as the Snoqualmie Valley).
Infrastructure Proximity: The PEIS must not treat proximity to existing electrical substations or transmission lines as a proxy for environmental or community suitability.
Q3 · Environmental & Community Impacts to Analyze
The PEIS must model realistic, worst-case catastrophic events and their cascading direct, indirect, and cumulative environmental impacts:
Atmospheric Dispersion & Valley Inversion: Model toxic gas emissions (including Hydrogen Fluoride, Hydrogen Cyanide, and Carbon Monoxide) during thermal runaway events using local atmospheric models that specifically account for valley thermal inversions, where stagnant air traps toxic smoke plumes near ground level.
Offsite Human Health Risks: Evaluate toxic plume exposure for unprotected neighborhood residents and schoolchildren who lack firefighter PPE and may be unable to evacuate due to traffic bottlenecks.
Contaminated Firewater Runoff: Quantify the volume and chemical composition of fire-suppression water required during a multi-day thermal runaway event. Trace its migration path into shallow groundwater, private drinking wells, and local fish-bearing surface waters.
Emergency Response & Infrastructure Strain: Analyze the multi-day operational burden placed on local rural fire districts, HazMat teams, regional hospitals, and evacuation corridors (e.g., SR 202, SR 18, I-90).
Acoustic Environment: Model low-frequency, continuous nighttime noise impacts generated by industrial HVAC units and power inverters at distances exceeding 1,000 feet in quiet rural/suburban baselines.
Cumulative Impacts: Analyze the compounding risks of clustering multiple BESS facilities along the same utility corridor or watershed.
Q4 · Required Mitigation Measures & Regulatory Boundaries
The PEIS must provide concrete, enforceable mitigation strategies that local agencies (such as King County) can rely upon during project-level review:
Mandatory Siting Setbacks: Establish science-based minimum separation distances (setbacks) from homes, schools, hospitals, critical public infrastructure, and drinking-water wells.
Safety Protocols: Require facility-specific UL 9540A unit-, system-, and structure-level fire test data prior to project approval.
First Responder Support: Require developer-funded specialized equipment, continuous HazMat training, and dedicated fire-suppression infrastructure for local fire districts prior to facility commissioning.
Water Containment: Mandate secondary and tertiary containment systems engineered to capture 100% of contaminated firewater and chemical coolant leaks onsite.
Financial Assurance: Recommend developer-funded environmental monitoring, strict liability insurance, and mandatory decommissioning bonds to ensure site remediation without public expense.
Local Authority: State clearly that state standards represent a regulatory floor, not a ceiling, and that local jurisdictions retain the authority to enforce stricter local zoning, noise, and safety protections.
Unavoidable Adverse Impacts: Where impacts cannot be mitigated below significance (such as a catastrophic fire exceeding rural response capacity), the Draft PEIS must state this plainly as an unavoidable significant adverse impact under SEPA.
Conclusion
Because stand-alone BESS facilities "could be sited in a variety of locations" across Washington, proximity to residential communities and vulnerable environmental features must be treated as a core condition of your programmatic analysis.
Thank you for accepting and considering this scoping comment. Please keep me informed of all future notices, public hearings, and the release of the Draft PEIS for Publication No. 26-06-017.
Sincerely,
Vasileios Zois
6506 Douglas Avenue Southeast
Snoqualmie, WA 98065↓
This PEIS directly impacts my family and community. A stand-alone utility-scale BESS facility is currently proposed in the Snoqualmie Valley, in close proximity to residential neighborhoods and Quantum STEM School, which my child attends. Furthermore, our community relies on single-access transit corridors—including SR 202, SR 18, and I-90—which serve as vital daily transit and sole emergency evacuation routes for valley residents.
Because Ecology has explicitly stated that future project-level SEPA reviews will tier to this PEIS, and because stand-alone facilities are increasingly being proposed near populated suburban communities rather than remote industrial zones, this PEIS must evaluate real-world siting conditions. I request that Ecology incorporate the following key parameters into the PEIS scope:
Key Scoping Requests
Q1 · Facility Types & Baseline Standards
The PEIS must evaluate the full operational spectrum of stand-alone, containerized lithium-ion BESS installations as they are actually being proposed in Washington State, specifically those sited near residential neighborhoods, schools, and constrained transportation corridors.
Code Baseline vs. Modern Standards: The PEIS should explicitly model risks based on the building and fire codes Washington has currently adopted, while evaluating updated safety standards—such as the most recent edition of NFPA 855 and full-scale UL 9540A fire testing—as essential, mandatory mitigation measures rather than optional upgrades.
Independent Failure Data: Safety, failure-rate, and thermal runaway analyses must rely on independent, peer-reviewed safety data rather than self-reported or industry-funded research data.
Expanded Definition of Harm: The study must define offsite impacts to include mandatory evacuations, shelter-in-place orders, prolonged community displacement, and hazardous waste remediation—not just direct fire or structural damage.
Q2 · Geographic Scope & Site-Suitability Screening
Suitability must be defined by public health, safety, and environmental protection—not merely electrical grid proximity or land availability.
Exclusionary Screening Criteria: The PEIS geographic scope should establish clear environmental and safety screening thresholds. Siting assumptions must explicitly account for and screen out:
Proximity to high-density residential areas, schools, child-care facilities, and medical centers.
Areas dependent on private drinking-water wells or located within critical aquifer recharge areas.
100-year floodplains, liquefaction zones, and mapped seismic fault lines.
Wildland-Urban Interface (WUI) and fire-prone zones.
Communities with constrained egress or single-road evacuation bottlenecks (such as the Snoqualmie Valley).
Infrastructure Proximity: The PEIS must not treat proximity to existing electrical substations or transmission lines as a proxy for environmental or community suitability.
Q3 · Environmental & Community Impacts to Analyze
The PEIS must model realistic, worst-case catastrophic events and their cascading direct, indirect, and cumulative environmental impacts:
Atmospheric Dispersion & Valley Inversion: Model toxic gas emissions (including Hydrogen Fluoride, Hydrogen Cyanide, and Carbon Monoxide) during thermal runaway events using local atmospheric models that specifically account for valley thermal inversions, where stagnant air traps toxic smoke plumes near ground level.
Offsite Human Health Risks: Evaluate toxic plume exposure for unprotected neighborhood residents and schoolchildren who lack firefighter PPE and may be unable to evacuate due to traffic bottlenecks.
Contaminated Firewater Runoff: Quantify the volume and chemical composition of fire-suppression water required during a multi-day thermal runaway event. Trace its migration path into shallow groundwater, private drinking wells, and local fish-bearing surface waters.
Emergency Response & Infrastructure Strain: Analyze the multi-day operational burden placed on local rural fire districts, HazMat teams, regional hospitals, and evacuation corridors (e.g., SR 202, SR 18, I-90).
Acoustic Environment: Model low-frequency, continuous nighttime noise impacts generated by industrial HVAC units and power inverters at distances exceeding 1,000 feet in quiet rural/suburban baselines.
Cumulative Impacts: Analyze the compounding risks of clustering multiple BESS facilities along the same utility corridor or watershed.
Q4 · Required Mitigation Measures & Regulatory Boundaries
The PEIS must provide concrete, enforceable mitigation strategies that local agencies (such as King County) can rely upon during project-level review:
Mandatory Siting Setbacks: Establish science-based minimum separation distances (setbacks) from homes, schools, hospitals, critical public infrastructure, and drinking-water wells.
Safety Protocols: Require facility-specific UL 9540A unit-, system-, and structure-level fire test data prior to project approval.
First Responder Support: Require developer-funded specialized equipment, continuous HazMat training, and dedicated fire-suppression infrastructure for local fire districts prior to facility commissioning.
Water Containment: Mandate secondary and tertiary containment systems engineered to capture 100% of contaminated firewater and chemical coolant leaks onsite.
Financial Assurance: Recommend developer-funded environmental monitoring, strict liability insurance, and mandatory decommissioning bonds to ensure site remediation without public expense.
Local Authority: State clearly that state standards represent a regulatory floor, not a ceiling, and that local jurisdictions retain the authority to enforce stricter local zoning, noise, and safety protections.
Unavoidable Adverse Impacts: Where impacts cannot be mitigated below significance (such as a catastrophic fire exceeding rural response capacity), the Draft PEIS must state this plainly as an unavoidable significant adverse impact under SEPA.
Conclusion
Because stand-alone BESS facilities "could be sited in a variety of locations" across Washington, proximity to residential communities and vulnerable environmental features must be treated as a core condition of your programmatic analysis.
Thank you for accepting and considering this scoping comment. Please keep me informed of all future notices, public hearings, and the release of the Draft PEIS for Publication No. 26-06-017.
Sincerely,
Vasileios Zois
6506 Douglas Avenue Southeast
Snoqualmie, WA 98065↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Marla Gass and I live at 7832 Cortland Ave SE, Snoqualmie. I am writingu to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scal...↓e, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people, domestic animals and wildlife living nearby. The scoping document acknowledges toxic gas from damaged batteries can do harm to firefighters' lungs and skin. However, it does not consider neighbors, who have NO protective gear and in many instances won't be able to evacuate. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example of the "Moss Landing" fire that forced 1,200 people from their homes is evidence. In September 2026, "Moss Landing" has suffered yet another event. Even before the September 2026 event they were unsuccessful in their cleanup efforts from the previous fires of January 2025. It is also imperative that a study be done to measure nighttime noise at the nearest homes, NOT at the fence line. Ecology's earlier studies found that noise from these types of facilities can reach 1,000 feet in rural areas. Receiving a full analysis for responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup, can't be just a mention, as the Ecology study scoping document states it "will evaluate" each of them. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Marla Gass
7832 Cortland Ave SE, Snoqualmie↓
My name is Marla Gass and I live at 7832 Cortland Ave SE, Snoqualmie. I am writingu to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scal...↓e, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people, domestic animals and wildlife living nearby. The scoping document acknowledges toxic gas from damaged batteries can do harm to firefighters' lungs and skin. However, it does not consider neighbors, who have NO protective gear and in many instances won't be able to evacuate. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example of the "Moss Landing" fire that forced 1,200 people from their homes is evidence. In September 2026, "Moss Landing" has suffered yet another event. Even before the September 2026 event they were unsuccessful in their cleanup efforts from the previous fires of January 2025. It is also imperative that a study be done to measure nighttime noise at the nearest homes, NOT at the fence line. Ecology's earlier studies found that noise from these types of facilities can reach 1,000 feet in rural areas. Receiving a full analysis for responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup, can't be just a mention, as the Ecology study scoping document states it "will evaluate" each of them. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Marla Gass
7832 Cortland Ave SE, Snoqualmie↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Sydney Zvara and I live at 7252 Fairway Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. Our neighborhood children attend school very near a proposed stand-alone BESS site and play at the park that adjoins it. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sydney Zvara
7252 Fairway Ave SE↓
My name is Sydney Zvara and I live at 7252 Fairway Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. I ask that Ecology not define "suitable" areas by grid proximity alone, and that the geographic-scope assumptions screen for nearby homes and schools, wildfire exposure, mapped seismic and flood hazards, private-well dependence, and limited evacuation routes.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the impact analysis cover battery-fire smoke and hydrogen fluoride under valley inversion conditions, fire-suppression runoff reaching wells and salmon streams, the load a multi-day incident puts on rural fire, HazMat, hospital, and evacuation capacity, all-night mechanical noise well past 1,000 feet, and how container-based facilities perform in an earthquake.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. Our neighborhood children attend school very near a proposed stand-alone BESS site and play at the park that adjoins it. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Sydney Zvara
7252 Fairway Ave SE↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Wallace Gass and I live at 7832 Cortland Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 ·Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people and wildlife living nearby. The scoping document acknowledges toxic gas from damaged batteries can harm firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave their homes. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I am a Licensed Real Estate Broker, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Wallace Gass
7832 Cortland Ave SE↓
My name is Wallace Gass and I live at 7832 Cortland Ave SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-...↓ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 ·Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people and wildlife living nearby. The scoping document acknowledges toxic gas from damaged batteries can harm firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave their homes. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I am a Licensed Real Estate Broker, and I offer this comment with that professional background.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Wallace Gass
7832 Cortland Ave SE↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Georgia North and I live at 38347 SE Northern Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lit...↓hium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area. My household depends on SR 202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Georgia North
38347 SE Northern Street↓
My name is Georgia North and I live at 38347 SE Northern Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lit...↓hium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live downstream or downwind of a proposed stand-alone BESS site, in the same air basin, fire district, and hospital service area. My household depends on SR 202, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Georgia North
38347 SE Northern Street↓
No attachments
Please find attached a letter from the City of Sumner commenting on the scoping for the PEIS on BESS. Thank you for the opportunity to comment on this important document.
Attachments:
To the Department of Ecology, Clean Energy Coordination:
My name is Scott C Hagen and I live at 38429 SE 47th Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household drinking water comes from a private well. My household depends on I-90, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Scott C Hagen
38429 SE 47th Street↓
My name is Scott C Hagen and I live at 38429 SE 47th Street. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household drinking water comes from a private well. My household depends on I-90, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Scott C Hagen
38429 SE 47th Street↓
No attachments
To the Department of Ecology, Clean Energy Coordination:
My name is Fariha and I live in a Washington community where there is currently a proposed battery facility. I am writing to submit a scoping comment on the Programmatic Environmental Impact S...↓tatement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. Kids attend school near a proposed stand-alone BESS site. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Fariha↓
My name is Fariha and I live in a Washington community where there is currently a proposed battery facility. I am writing to submit a scoping comment on the Programmatic Environmental Impact S...↓tatement for stand-alone, utility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q2 · Geographic scope — Where the study assumes batteries will go.
Closeness to existing infrastructure should not be used as a stand-in for a safe site. Being near a substation should not make a place "suitable." The Ecology study should define "suitable" areas by what is safe for the people who live there, not just by where a facility could physically be built. The study's map should clearly say where facilities should not go, not only where they could, since nearly every kind of land is in play. Conditions like those in the Snoqualmie Valley should be part of what the study considers, because this is the one chance to shape the study area before Ecology draws it. I ask that the PEIS's geographic-scope assumptions explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes — and that proximity to existing infrastructure not be treated as a proxy for suitability.
Q3 · Impacts to analyze — The harms the study has to look at.
It's crucial that responder training, hard-to-extinguish fires, toxic air, harm to water and fish, and cleanup each get a full analysis, not a mention, as the Ecology study scoping document states it "will evaluate" each of them. It's important that the study model what a battery fire's smoke does to the people living nearby. The scoping document acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention neighbors, who have no protective gear and may not be able to leave. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes. The study needs to measure nighttime noise at the nearest home, not at the fence line, since Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
Q4 · Mitigation — The steps Ecology should require to reduce the harm.
I would like the study to name specific, measurable protections a permit can require. Protections described "at a high level" give my county nothing to write into a permit. The study should be specific enough to give local reviewers something to hold a developer to, because my county will lean on it when it reviews a real project. The siting and design considerations Ecology plans to give developers from the study must include minimum distances from homes, schools, hospitals, and drinking-water wells that are proven to be safe for the surrounding community, not just general guidelines. The study should recommend large-scale fire testing be required for every facility, whether or not the state has adopted the newest code, since Ecology itself credits it with reducing risk. I ask that the PEIS identify concrete mitigation measures, including minimum setbacks from homes, schools, hospitals, and drinking-water wells; large-scale fire testing (UL 9540A) and compliance with the current edition of NFPA 855 regardless of state adoption status; funded emergency-response plans, training, and equipment for local fire districts before operation; containment and disposal plans for fire-suppression water; enforceable nighttime noise limits at the nearest residence; and decommissioning and financial-assurance requirements.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. Kids attend school near a proposed stand-alone BESS site. My household depends on Snoqualmie Parkway, which is also an emergency route for everyone along it.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Fariha↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Ingrid Yenin and I live at 14607 Main St, A103. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I'm deeply concerned about this situation and this project plan: we are creating serious safety issues and medical safety concerns related to long term health issues due to various factors including high air pollution levels, noise pollution levels and fires caused by these chemicals in the facility. Washington state is currently plaques with wildfires every year. Facility like this is an everyday concern and anxiety for residents. It must not be built in the residential area or so close to it. Residents opinions must be heard and taken into consideration. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live elsewhere in Washington, near the kind of grid infrastructure Ecology says may make a place "suitable" for a facility like this.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Ingrid Yenin
14607 Main St, A103↓
My name is Ingrid Yenin and I live at 14607 Main St, A103. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium-i...↓on battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS. Ecology has asked for input on questions for the study. My comment addresses the following:
Q3 · Impacts to analyze — The harms the study has to look at.
I'm deeply concerned about this situation and this project plan: we are creating serious safety issues and medical safety concerns related to long term health issues due to various factors including high air pollution levels, noise pollution levels and fires caused by these chemicals in the facility. Washington state is currently plaques with wildfires every year. Facility like this is an everyday concern and anxiety for residents. It must not be built in the residential area or so close to it. Residents opinions must be heard and taken into consideration. I ask that the PEIS analyze, for stand-alone facilities: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live elsewhere in Washington, near the kind of grid infrastructure Ecology says may make a place "suitable" for a facility like this.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance, so that lead agencies and the public are not left to guess.
Thank you for considering this comment. Please include it in the scoping record. Our community is following this PEIS closely and intends to participate in the Draft PEIS comment period.
Sincerely,
Ingrid Yenin
14607 Main St, A103↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Natalie Carlson and I live at 7023 LAUREL AVE SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS.
I want to the Department of Ecology to ensure that BESS developers have done thorough studies and reporting on the various ways the facilities will and could affect the surrounding community and environment.
↓
My name is Natalie Carlson and I live at 7023 LAUREL AVE SE. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, utility-scale, lithium...↓-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because Washington is siting stand-alone battery facilities near communities, including one proposed in the Snoqualmie Valley, and Ecology has said that project-level reviews will tier to this PEIS.
I want to the Department of Ecology to ensure that BESS developers have done thorough studies and reporting on the various ways the facilities will and could affect the surrounding community and environment.
↓
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To the Department of Ecology, Clean Energy Coordination:
My name is Teresa Bechtold and I live at 35328 SE Kinsey Street, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ut...↓ility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology states project-level reviews will tier to this PEIS. Ecology asked for input on questions for the study. My comment addresses geographic scope and what studies should be required:
Q2 · Geographic scope — The Ecology study should define "suitable" areas by what is safe for the people who live there. Proximity to existing substations should not be used as a stand-in for a safe site. Existing substations weren't built for energy storage: they were built to translate high voltage into lower voltage usable by homes, schools, and small businesses. The study's map should clearly say where facilities should not go, and eliminate places with private wells, floodplains, earthquake faults, and neighborhoods with limited evacuation routes. Wildfire exposure and fire-district capacity should be part of the map, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities." The PEIS's geographic-scope assumptions should explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes. Proximity to existing infrastructure isn't a proxy for suitability.
Q3 · Impacts to analyze — Adequate equipment and trained experts to extinguish industrial fires and evacuate all people from the toxic plume with at least two evacuation routes from the site should be fully analyzed and independently verified. Similarly, contamination of drinking water and riparian habitat should be fully analyzed. Ecology's scoping document states it "will evaluate" each of those areas but doesn't demand independent scientific data specific to the proposed site. Ecology's study should model what a battery fire's smoke does to the people and wildlife living nearby. Ecology acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention residents who have no protective gear and may not be able to escape. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes in 2025 and forced people from their homes again when it reignited in 2026 during EPA cleanup. Nighttime noise should be measured at the nearest homes; Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. For stand-alone facilities the PEIS should analyze: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling, including for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Railroad Ave / SR 202, which is also an emergency route for everyone along it. Our neighborhood suffered severe flooding in December, 2025 and couldn't flee a toxic plume the BESS envisioned in Ecology's draft produces.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance.
Thank you for considering how best to protect our environment and include this comment in the scoping record.
Kind regards,
Teresa Bechtold
35328 SE Kinsey Street, Snoqualmie, WA↓
My name is Teresa Bechtold and I live at 35328 SE Kinsey Street, Snoqualmie, WA. I am writing to submit a scoping comment on the Programmatic Environmental Impact Statement for stand-alone, ut...↓ility-scale, lithium-ion battery energy storage system facilities in Washington (Publication 26-06-017).
I am commenting because a stand-alone BESS facility is proposed near where I live, and Ecology states project-level reviews will tier to this PEIS. Ecology asked for input on questions for the study. My comment addresses geographic scope and what studies should be required:
Q2 · Geographic scope — The Ecology study should define "suitable" areas by what is safe for the people who live there. Proximity to existing substations should not be used as a stand-in for a safe site. Existing substations weren't built for energy storage: they were built to translate high voltage into lower voltage usable by homes, schools, and small businesses. The study's map should clearly say where facilities should not go, and eliminate places with private wells, floodplains, earthquake faults, and neighborhoods with limited evacuation routes. Wildfire exposure and fire-district capacity should be part of the map, since Ecology's own earlier studies flagged wildfire risk from "new ignition sources in remote locations with limited response capabilities." The PEIS's geographic-scope assumptions should explicitly account for proximity to homes, schools, and hospitals; wildland-urban interface and wildfire-prone areas; seismic hazard zones and floodplains; areas dependent on private wells; and communities with limited evacuation routes. Proximity to existing infrastructure isn't a proxy for suitability.
Q3 · Impacts to analyze — Adequate equipment and trained experts to extinguish industrial fires and evacuate all people from the toxic plume with at least two evacuation routes from the site should be fully analyzed and independently verified. Similarly, contamination of drinking water and riparian habitat should be fully analyzed. Ecology's scoping document states it "will evaluate" each of those areas but doesn't demand independent scientific data specific to the proposed site. Ecology's study should model what a battery fire's smoke does to the people and wildlife living nearby. Ecology acknowledges toxic gas from damaged batteries can hurt firefighters' skin and lungs. It does not mention residents who have no protective gear and may not be able to escape. Evacuation, displacement, and offsite cleanup should count as impacts in their own right. Ecology's own example, the Moss Landing fire, forced 1,200 people from their homes in 2025 and forced people from their homes again when it reignited in 2026 during EPA cleanup. Nighttime noise should be measured at the nearest homes; Ecology's earlier studies found that noise from these facilities reaches 1,000 feet in quiet rural areas. For stand-alone facilities the PEIS should analyze: thermal-runaway fires and hazardous-gas emissions (including hydrogen fluoride) with dispersion modeling, including for inversion-prone valleys; contaminated fire-suppression water and its path to groundwater, private wells, and fish-bearing streams; multi-day incident demands on local fire, HazMat, hospital, and evacuation capacity; continuous nighttime noise from cooling and inverters at distances beyond 1,000 feet; and seismic performance of container-based installations in mapped fault zones.
This is personal for my household. I live near a site where a stand-alone BESS facility is proposed. My household depends on Railroad Ave / SR 202, which is also an emergency route for everyone along it. Our neighborhood suffered severe flooding in December, 2025 and couldn't flee a toxic plume the BESS envisioned in Ecology's draft produces.
Because Ecology itself says stand-alone facilities "could be sited in a variety of locations," including near cities, the PEIS should not assume facilities will be far from people. I ask that Ecology treat proximity to residents as a defining condition of the analysis, and that the Draft PEIS state plainly which impacts cannot be mitigated below significance.
Thank you for considering how best to protect our environment and include this comment in the scoping record.
Kind regards,
Teresa Bechtold
35328 SE Kinsey Street, Snoqualmie, WA↓
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I have two issues associated with this project, the technology chosen for storage, lithium batteries and location. Lithium batteries are known to catch on fire and difficult to extinguish plus emit toxic fumes. This leads to the second issue, proximi...↓ty to community. The location chosen is near a forest and residential housing with an area that has high winds. The proximity to housing limits the time for people to evacuate combined with limited egress routes. There are other ecological issues also with contamination of waterways etc. In preparing criteria I believe that the technology should be safe and location near populated areas excluded based on proposed battery type.
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