CETA and Grid Storage
What is CETA?
The Clean Energy Transformation Act (CETA), passed by Washington State in 2019, requires the state’s electric utilities to:
- Eliminate coal from their power supply by 2025
- Be greenhouse gas neutral by 2030
- Supply 100% clean electricity by 2045
CETA applies to all investor-owned utilities and consumer-owned utilities serving more than 25,000 customers. Puget Sound Energy (PSE), which serves the Snoqualmie Valley, is subject to all three milestones.
Why storage matters
Wind and solar generation don’t match when people use electricity. Solar peaks midday; demand peaks in the evening. Wind is intermittent. To meet CETA’s requirements without fossil fuel backup, utilities need a way to store clean energy and dispatch it when the grid needs it.
Battery energy storage systems (BESS) fill that gap. They charge when renewables are producing more than the grid needs and discharge during peak demand. Without storage, utilities face two bad options: overbuild generation capacity (expensive, and ratepayers pay for it) or keep fossil fuel peakers running (which violates CETA).
PSE’s situation
PSE’s 2024 RFP sought two things: up to 2.3 million annual MWh of CETA-eligible clean energy, and up to 1,755 MW of summer peak capacity and 1,573 MW of winter peak capacity. These are related but distinct needs:
- Clean energy (CETA): Replace fossil generation with renewable sources by the 2030 and 2045 targets. This is the policy-driven requirement.
- Peak capacity (reliability): Have enough generation and storage available to meet demand on the hottest and coldest days of the year. This is a grid reliability requirement that exists regardless of CETA.
Battery storage primarily serves the capacity need. It doesn’t generate clean energy; it shifts it in time. PSE needs storage because peak demand exceeds what intermittent renewables can deliver at the moment people need it. That’s a grid reliability problem that would exist with or without CETA. CETA constrains what type of resources can fill the gap (they must be clean), but the capacity gap itself is driven by demand growth and the retirement of aging generation.
PSE ran a voluntary All-Source RFP in July 2024 (UTC Docket UE-240532) and received 98 proposals. The Cascadia Ridge tolling agreement was one result, signed August 22, 2025 and filed with the UTC on September 19, 2025.
What PSE was offered
The aggregated proposal summary (docID 16, filed October 17, 2024) lists all 98 proposals:
| Resource type | Proposals | States |
|---|---|---|
| Storage: Battery Li-ion 4hr | 47 | WA (41), OR (4), MT (2) |
| Solar: PV | 18 | WA (10), OR (5), ID (2), MT (1) |
| Hybrid: Solar + Storage | 15 | WA (11), OR (2), MT (2) |
| Wind | 11 | MT (5), OR (3), WA (3) |
| Flex Capacity: Gas | 5 | WA (5) |
| Storage: Pumped Hydro | 3 | OR (2), MT (1) |
Every single battery storage proposal was lithium-ion, 4-hour duration. All 47 standalone storage proposals. All 15 solar+storage hybrids. Not one sodium-ion proposal. Not one alternative chemistry.
That’s because the RFP closed in September 2024, before sodium-ion reached commercial scale. PSE selected from what was offered. They didn’t have a chemistry choice.
The technology landscape has changed since the RFP closed. Peak Energy delivered the first US grid-scale sodium-ion system in 2025, CATL is mass-producing sodium-ion cells in 2026, and Jupiter Power has already contracted for 4.75 GWh of Peak Energy sodium-ion for other projects. A full EIS alternatives analysis would require evaluation of whether commercially available chemistries that eliminate thermal runaway are feasible at this site. Without an EIS, that question never enters the public record.
WA standalone battery proposals ranged from 40 MW to 400 MW. Cascadia Ridge at 130 MW is mid-range. Five gas plant proposals (171-215 MW) were also submitted, the fossil peakers CETA is supposed to replace.
RFP process and oversight
PSE’s 2024 RFP was voluntary under WAC 480-107-021(1). That means the UTC does not formally approve or disapprove the RFP or the resulting contracts. Agreements are filed for informational purposes only.
The Northwest & Intermountain Power Producers Coalition (NIPPC) raised concerns about this structure in July 2024:
- The voluntary process lets PSE avoid Commission oversight and stakeholder input on resource selection
- The 50/50 price/non-price scoring may bias toward utility-owned resources (NIPPC recommended 80/20)
- Imputed debt adders may penalize power purchase agreements and tolling agreements relative to utility-owned assets
The UTC acknowledged but did not act on these concerns.
What PSE actually scored
The evaluation rubric (Exhibit A.1, filed July 1, 2024) is public. The non-price criteria, worth 50% of the total score, evaluated only project readiness:
| Category | Weight | What it measures |
|---|---|---|
| Site Control | 5% | Does the developer control the land? |
| Permitting and Studies | 15% | Are permits filed? Are environmental studies done? |
| Interconnection Service | 10% | Is the project in the interconnection queue? |
| Transmission Service | 20% | Is firm transmission secured? |
Battery chemistry is not in the rubric. Community safety is not in the rubric. Proximity to residential areas, schools, or hospitals is not in the rubric. Consistency with PSE’s own ESS Location Study is not in the rubric.
There is one criterion worth a single point under Permitting: “Project has not received significant opposition from Tribes, interested parties or impacted local landowners.” Opposition is treated as a schedule risk to the developer, not as a signal that the site may be wrong.
PSE’s evaluation literally did not ask what kind of battery would be installed in the middle of the Snoqualmie Valley, adjacent to the City of Snoqualmie (population 14,550 per the Washington State Office of Financial Management’s April 1, 2025 official estimate).
Transparency
PSE originally filed the Cascadia Ridge tolling agreement with the UTC redacted in its entirety under WAC 480-07-160. A partially redacted version was later secured, but pricing, payment terms, technical specifications, and battery chemistry requirements remain redacted. PSE filed suit on April 9, 2026 (PSE v. WUTC, Thurston County Superior Court) to prevent further disclosure. The Dry Falls energy storage tolling agreement, the only other BESS agreement filed from this RFP, is also redacted in its entirety.
UTC Commission Staff filed comments on the 2021 RFP process on March 20, 2025 that directly addressed this pattern. Staff wrote that “some information that PSE redacted in the IE’s final report does not appear to Staff to be commercially sensitive” and encouraged PSE to be “judicious in its redactions to ensure meaningful transparency for customers, interested persons, and the public.” NIPPC separately noted in its March 24 comments that it could not submit extensive comments because it “does not have access to the confidential information.”
The community adjacent to this facility cannot see the contract that governs what is being built next to their homes.
Prudence review
The financial lever comes later. When PSE seeks to recover Cascadia Ridge costs in customer rates (in a future general rate case), the UTC will conduct a prudence review. Intervenors — including Public Counsel, which represents ratepayers — can challenge whether the agreement was prudent: was it the lowest reasonable cost? Were alternatives adequately considered? Did community opposition, permitting delays, or environmental concerns affect the project’s cost or viability?
If the project faces significant community opposition or permitting complications, those factors could weigh against a finding of prudence.
Storage is coming regardless
CETA creates a specific timeline for PSE, but grid storage is being built across the country even in states with no clean energy mandate. Texas has no state clean energy requirement and is one of the largest BESS markets in the country. Jupiter Power is based there and does most of its business there. The driver is economics: solar is now the cheapest form of new electricity generation, and storage makes it dispatchable. Solar plus storage undercuts new gas peakers on cost in most markets without any mandate.
Battery costs have dropped roughly 90% in the last decade. The federal Inflation Reduction Act provides standalone storage tax credits. FERC Order 841 opened wholesale electricity markets to storage. These trends don’t depend on CETA.
The debate isn’t whether to build storage. Storage is inevitable. The debate is whether a 130 MW facility can operate safely at this particular site, adjacent to thousands of homes in a constrained valley. That question requires the level of analysis only a full Environmental Impact Statement can provide.
Our position
We support grid storage. It’s needed for CETA compliance, and it makes economic sense. The Mt. Si substation next to the Cascadia Ridge site is a real interconnection point. But PSE’s own siting consultant screened it out on electrical criteria before community factors were even evaluated, and the study’s “Good Neighbor” test would also flag what surrounds it: residential areas, schools, and limited evacuation routes. The site raises questions about toxic gas dispersion, seismic hazard, emergency response, and groundwater that a SEPA checklist cannot credibly evaluate. We are asking King County to require a full Environmental Impact Statement before permitting this project.